https://www.taxtmi.com/caselaws?id=175426 A notice reopening assessment under section 34(1)(a) of the Income-tax Act, 1922 must identify the relevant assessment year with certainty, because it is a condition precedent to reassessment. Different documents may be read together only if they are shown to be related and intended as one composite notice. Here, one notice referred to assessment year 1949-50 while the accompanying notice under section 22(2) referred to 1950-51, with no indication that they were complementary. The contradiction on the assessment year destroyed the requisite clarity, so the reopening notice was invalid and reassessment could not be sustained. en-us Wed, 08 Sep 1965 00:00:00 +0530 Sat, 14 May 2022 13:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175426 A notice reopening assessment under section 34(1)(a) of the Income-tax Act, 1922 must identify the relevant assessment year with certainty, because it is a condition precedent to reassessment. Different documents may be read together only if they are shown to be related and intended as one composite notice. Here, one notice referred to assessment year 1949-50 while the accompanying notice under section 22(2) referred to 1950-51, with no indication that they were complementary. The contradiction on the assessment year destroyed the requisite clarity, so the reopening notice was invalid and reassessment could not be sustained. Case-Laws Income Tax Wed, 08 Sep 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175426