https://www.taxtmi.com/caselaws?id=68255 Reopening under Section 147 read with Section 148 requires the Assessing Officer to record independent reasons showing that income chargeable to tax has escaped assessment before issuing notice. Mechanical endorsement of an Inspector's report is not a valid substitute for such reasons, and a bare reference to gross receipts without enquiry into expenditure or net income is insufficient to form the required belief. The text states that non-compliance with the mandatory requirement under Section 148(2) leaves the reassessment notice without legal foundation, rendering the reassessment proceedings invalid and the notice liable to be quashed. en-us Tue, 29 Jun 1982 00:00:00 +0530 Sat, 03 Sep 2011 18:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=68255 Reopening under Section 147 read with Section 148 requires the Assessing Officer to record independent reasons showing that income chargeable to tax has escaped assessment before issuing notice. Mechanical endorsement of an Inspector's report is not a valid substitute for such reasons, and a bare reference to gross receipts without enquiry into expenditure or net income is insufficient to form the required belief. The text states that non-compliance with the mandatory requirement under Section 148(2) leaves the reassessment notice without legal foundation, rendering the reassessment proceedings invalid and the notice liable to be quashed. Case-Laws Income Tax Tue, 29 Jun 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=68255