https://www.taxtmi.com/caselaws?id=5693 Reopening of assessment under section 147(a) was upheld because the recorded reasons showed prima facie material suggesting undervaluation of closing stock and possible understatement of profits by excluding fiscal duty and direct manufacturing costs. At the threshold stage, the court held that only the existence of relevant material mattered; the sufficiency, correctness, or ultimate truth of the allegations could not be decided then. The assessee remained free to contest the factual basis before the assessing authority and to show that no new facts had emerged after the original assessment. The reopening could therefore not be invalidated at this stage. en-us Wed, 17 Dec 1997 00:00:00 +0530 Sat, 11 Oct 2025 08:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5693 Reopening of assessment under section 147(a) was upheld because the recorded reasons showed prima facie material suggesting undervaluation of closing stock and possible understatement of profits by excluding fiscal duty and direct manufacturing costs. At the threshold stage, the court held that only the existence of relevant material mattered; the sufficiency, correctness, or ultimate truth of the allegations could not be decided then. The assessee remained free to contest the factual basis before the assessing authority and to show that no new facts had emerged after the original assessment. The reopening could therefore not be invalidated at this stage. Case-Laws Income Tax Wed, 17 Dec 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5693