https://www.taxtmi.com/caselaws?id=6193 Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 could be initiated only where the Income-tax Officer had reason to believe both that income had escaped assessment and that the escapement resulted from the assessee's failure to disclose fully and truly all material facts. That belief had to rest on relevant material, with a rational connection to the recorded reasons; a bare assertion of belief was not enough. Because the officer produced no affidavit and the reasons, report to the Commissioner, and sanction were not shown, the jurisdictional basis for the notices was not established, and the reassessment notices were held without jurisdiction and quashed. en-us Thu, 16 Apr 1970 00:00:00 +0530 Tue, 01 Jul 2025 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6193 Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 could be initiated only where the Income-tax Officer had reason to believe both that income had escaped assessment and that the escapement resulted from the assessee's failure to disclose fully and truly all material facts. That belief had to rest on relevant material, with a rational connection to the recorded reasons; a bare assertion of belief was not enough. Because the officer produced no affidavit and the reasons, report to the Commissioner, and sanction were not shown, the jurisdictional basis for the notices was not established, and the reassessment notices were held without jurisdiction and quashed. Case-Laws Income Tax Thu, 16 Apr 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6193