https://www.taxtmi.com/caselaws?id=5005 A writ court should not quash a reassessment notice on a factual or jurisdictional ground that was not pleaded or put in issue, because a new case cannot be introduced without foundational averments. The record must support any challenge that the notice lacked the requisite reasons to believe that income had escaped assessment by reason of nondisclosure of material facts; on the materials referred to in the text, that belief was shown and the notice was treated as valid. Allegations of non-recording of reasons and mala fides also fail where they were neither properly pleaded nor supported by the record. The reassessment notice was therefore upheld. en-us Mon, 10 Oct 1966 00:00:00 +0530 Tue, 18 Nov 2008 16:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5005 A writ court should not quash a reassessment notice on a factual or jurisdictional ground that was not pleaded or put in issue, because a new case cannot be introduced without foundational averments. The record must support any challenge that the notice lacked the requisite reasons to believe that income had escaped assessment by reason of nondisclosure of material facts; on the materials referred to in the text, that belief was shown and the notice was treated as valid. Allegations of non-recording of reasons and mala fides also fail where they were neither properly pleaded nor supported by the record. The reassessment notice was therefore upheld. Case-Laws Income Tax Mon, 10 Oct 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5005