https://www.taxtmi.com/caselaws?id=65086 The Tribunal upheld the validity of reassessment proceedings under section 147, affirming that the Assessing Officer had valid reasons to believe income had escaped assessment, and the notice under section 148 was issued within the limitation period. However, a Third Member disagreed, finding the proceedings invalid due to non-application of mind by the Assessing Officer and initiation for investigative purposes, which is impermissible under section 147. The Tribunal emphasized the applicability of Explanation 2(b) to section 147, while the Third Member highlighted procedural deficiencies, ultimately resulting in a divided decision on the reassessment's validity. en-us Tue, 11 May 2004 00:00:00 +0530 Wed, 17 Jul 2024 15:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65086 The Tribunal upheld the validity of reassessment proceedings under section 147, affirming that the Assessing Officer had valid reasons to believe income had escaped assessment, and the notice under section 148 was issued within the limitation period. However, a Third Member disagreed, finding the proceedings invalid due to non-application of mind by the Assessing Officer and initiation for investigative purposes, which is impermissible under section 147. The Tribunal emphasized the applicability of Explanation 2(b) to section 147, while the Third Member highlighted procedural deficiencies, ultimately resulting in a divided decision on the reassessment's validity. Case-Laws Income Tax Tue, 11 May 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65086