https://www.taxtmi.com/caselaws?id=68070 Reopening under section 147(a) requires material that has a direct rational nexus with a bona fide belief that income has escaped assessment; mere suspicion is insufficient. On the facts, statements and documents suggesting under-invoicing did not provide adequate corroboration, and the reassessment on that basis was not sustainable. A fresh notice under section 148 also could not validly be issued while an earlier reassessment proceeding for the same year remained pending, because a pending proceeding cannot be treated as escaped assessment for fresh reopening. The resulting reassessment was therefore held invalid. en-us Fri, 29 Jul 1988 00:00:00 +0530 Wed, 16 Mar 2011 17:28:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=68070 Reopening under section 147(a) requires material that has a direct rational nexus with a bona fide belief that income has escaped assessment; mere suspicion is insufficient. On the facts, statements and documents suggesting under-invoicing did not provide adequate corroboration, and the reassessment on that basis was not sustainable. A fresh notice under section 148 also could not validly be issued while an earlier reassessment proceeding for the same year remained pending, because a pending proceeding cannot be treated as escaped assessment for fresh reopening. The resulting reassessment was therefore held invalid. Case-Laws Income Tax Fri, 29 Jul 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=68070