https://www.taxtmi.com/caselaws?id=6392 Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 requires the Income-tax Officer's own formation of belief, recorded reasons and the requisite sanction as jurisdictional preconditions; proceedings initiated only under section 34(1)(b) cannot be validated by the Tribunal as if they were under section 34(1)(a). On the facts stated, the conversion was impermissible and the reassessment failed. Service of notice by affixture at the assessee's residence was also held invalid on the facts. As the reassessment basis collapsed, the amount sought to be taxed under section 4(1)(b)(iii) could not be sustained and was not liable to tax. en-us Fri, 09 Feb 1973 00:00:00 +0530 Tue, 13 Jan 2026 22:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6392 Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 requires the Income-tax Officer's own formation of belief, recorded reasons and the requisite sanction as jurisdictional preconditions; proceedings initiated only under section 34(1)(b) cannot be validated by the Tribunal as if they were under section 34(1)(a). On the facts stated, the conversion was impermissible and the reassessment failed. Service of notice by affixture at the assessee's residence was also held invalid on the facts. As the reassessment basis collapsed, the amount sought to be taxed under section 4(1)(b)(iii) could not be sustained and was not liable to tax. Case-Laws Income Tax Fri, 09 Feb 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6392