https://www.taxtmi.com/caselaws?id=209899 Reassessment under section 147 requires the recorded reasons to show a definite, relevant and live nexus between the material relied upon and a belief that income chargeable to tax for the relevant year has escaped assessment. Vague or non-specific material cannot confer jurisdiction, especially where the reasons do not identify any document showing escapement for the year in question. On the facts discussed, the search material only reflected a combined revenue figure, part of which related to another business period, while the assessee had not commenced business during the relevant year and had no revenue for that year. The reopening was therefore held invalid and the assessment under section 143(3) read with section 147 was quashed. en-us Tue, 14 Jun 2011 00:00:00 +0530 Tue, 09 Jul 2013 12:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=209899 Reassessment under section 147 requires the recorded reasons to show a definite, relevant and live nexus between the material relied upon and a belief that income chargeable to tax for the relevant year has escaped assessment. Vague or non-specific material cannot confer jurisdiction, especially where the reasons do not identify any document showing escapement for the year in question. On the facts discussed, the search material only reflected a combined revenue figure, part of which related to another business period, while the assessee had not commenced business during the relevant year and had no revenue for that year. The reopening was therefore held invalid and the assessment under section 143(3) read with section 147 was quashed. Case-Laws Income Tax Tue, 14 Jun 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=209899