https://www.taxtmi.com/caselaws?id=6665 Reassessment notices issued beyond four years but within eight years under section 34 of the Indian Income-tax Act, 1922 required two jurisdictional conditions to coexist: the Income-tax Officer must have reason to believe that income escaped assessment or was under-assessed, and that the escapement was attributable to the assessee's omission or failure to make a return or to disclose fully and truly all material facts necessary for assessment. The affidavits supporting the notice did not contain the necessary averment and did not establish the second condition precedent, so the notice lacked jurisdictional validity and could not be sustained. en-us Wed, 15 Jan 1964 00:00:00 +0530 Sat, 31 Jan 2009 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6665 Reassessment notices issued beyond four years but within eight years under section 34 of the Indian Income-tax Act, 1922 required two jurisdictional conditions to coexist: the Income-tax Officer must have reason to believe that income escaped assessment or was under-assessed, and that the escapement was attributable to the assessee's omission or failure to make a return or to disclose fully and truly all material facts necessary for assessment. The affidavits supporting the notice did not contain the necessary averment and did not establish the second condition precedent, so the notice lacked jurisdictional validity and could not be sustained. Case-Laws Income Tax Wed, 15 Jan 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6665