https://www.taxtmi.com/caselaws?id=220864 An assessee who received the recorded reasons for reopening, participated in reassessment, and did not challenge the absence of a separate speaking order on its objections at the appropriate stage could not later revive that procedural grievance after the assessment was set aside under Section 263 and remitted for de novo consideration. In that setting, the matter stood restored to the Assessing Officer for fresh assessment, and the earlier objection to the Section 148 notice was no longer available. The reopening challenge was also assessed on the limited jurisdictional test applicable at the notice stage: whether there was reason to believe that income had escaped assessment, not proof of escapement. en-us Fri, 01 Feb 2013 00:00:00 +0530 Fri, 28 Jun 2013 14:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220864 An assessee who received the recorded reasons for reopening, participated in reassessment, and did not challenge the absence of a separate speaking order on its objections at the appropriate stage could not later revive that procedural grievance after the assessment was set aside under Section 263 and remitted for de novo consideration. In that setting, the matter stood restored to the Assessing Officer for fresh assessment, and the earlier objection to the Section 148 notice was no longer available. The reopening challenge was also assessed on the limited jurisdictional test applicable at the notice stage: whether there was reason to believe that income had escaped assessment, not proof of escapement. Case-Laws Income Tax Fri, 01 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220864