https://www.taxtmi.com/caselaws?id=186329 Reopening under Section 148 requires recorded reasons that disclose the factual basis for the Assessing Officer's belief that income has escaped assessment and show application of mind. A bare reproduction of statutory language, or a general assertion that the assessee did not fully and truly disclose material facts, is insufficient without supporting material or factual linkage. The HC therefore found the reopening notice invalid for want of adequate recorded reasons and jurisdiction, and the proceedings founded on it were set aside, with liberty to issue a fresh notice in accordance with law if justified. en-us Tue, 27 Apr 1993 00:00:00 +0530 Wed, 14 Sep 2016 16:33:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186329 Reopening under Section 148 requires recorded reasons that disclose the factual basis for the Assessing Officer's belief that income has escaped assessment and show application of mind. A bare reproduction of statutory language, or a general assertion that the assessee did not fully and truly disclose material facts, is insufficient without supporting material or factual linkage. The HC therefore found the reopening notice invalid for want of adequate recorded reasons and jurisdiction, and the proceedings founded on it were set aside, with liberty to issue a fresh notice in accordance with law if justified. Case-Laws Income Tax Tue, 27 Apr 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186329