https://www.taxtmi.com/caselaws?id=76937 HC held the reassessment notice issued under s.148 invalid and set it aside. The court found no basis for the AO to form the requisite belief that income had escaped assessment; Explanation 2(b) to s.147 requires the AO to "notice" understatement or excessive claim in a return on a reasonable foundation, not by arbitrary whim. While sufficiency of material is not for the court to test, the existence of a genuine belief is indispensable, and here no prudent person could reasonably have formed such belief. en-us Mon, 22 Feb 2010 00:00:00 +0530 Mon, 01 Sep 2025 10:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=76937 HC held the reassessment notice issued under s.148 invalid and set it aside. The court found no basis for the AO to form the requisite belief that income had escaped assessment; Explanation 2(b) to s.147 requires the AO to "notice" understatement or excessive claim in a return on a reasonable foundation, not by arbitrary whim. While sufficiency of material is not for the court to test, the existence of a genuine belief is indispensable, and here no prudent person could reasonably have formed such belief. Case-Laws Income Tax Mon, 22 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=76937