https://www.taxtmi.com/caselaws?id=172616 In reassessment proceedings under the Indian Income-tax Act, 1922, the phrase "reason to believe" makes the notice justiciable, so the Court may examine whether the Income-tax Officer's belief rested on relevant material. However, at the initial stage the assessee cannot insist on disclosure of the recorded reasons or sanction if disclosure would frustrate the proceedings. It is sufficient for the Court itself to inspect the materials and satisfy itself that the belief was formed on reasonable grounds. On that basis, the notice was treated as valid and the challenge failed. en-us Thu, 21 May 1959 00:00:00 +0530 Wed, 26 Aug 2015 11:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=172616 In reassessment proceedings under the Indian Income-tax Act, 1922, the phrase "reason to believe" makes the notice justiciable, so the Court may examine whether the Income-tax Officer's belief rested on relevant material. However, at the initial stage the assessee cannot insist on disclosure of the recorded reasons or sanction if disclosure would frustrate the proceedings. It is sufficient for the Court itself to inspect the materials and satisfy itself that the belief was formed on reasonable grounds. On that basis, the notice was treated as valid and the challenge failed. Case-Laws Income Tax Thu, 21 May 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=172616