https://www.taxtmi.com/caselaws?id=70174 Reopening under section 147(b) requires the Income-tax Officer to form his own belief, on the basis of information such as an audit note, that income has escaped assessment. Here, the recorded reasons and reply to the audit objection showed that the officer did not accept the audit view and instead treated the objection as meritless; the reopening was sought only to keep the matter alive within limitation if the department later accepted the objection. That did not satisfy the statutory requirement of an independent belief before notice under section 148, so the reassessment was held invalid and the addition in reassessment could not be sustained. en-us Mon, 24 Jul 1978 00:00:00 +0530 Thu, 14 Apr 2011 17:07:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70174 Reopening under section 147(b) requires the Income-tax Officer to form his own belief, on the basis of information such as an audit note, that income has escaped assessment. Here, the recorded reasons and reply to the audit objection showed that the officer did not accept the audit view and instead treated the objection as meritless; the reopening was sought only to keep the matter alive within limitation if the department later accepted the objection. That did not satisfy the statutory requirement of an independent belief before notice under section 148, so the reassessment was held invalid and the addition in reassessment could not be sustained. Case-Laws Income Tax Mon, 24 Jul 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70174