https://www.taxtmi.com/caselaws?id=7843 A reopening notice under the 1961 Act could not validly revive an assessment for 1949-50 where the power to reopen had already become barred under section 34 of the 1922 Act before the 1961 Act commenced. The old law permitted reopening after eight years only if escaped income had amounted to, or was likely to amount to, the prescribed threshold, and the materials did not show that condition. The phrase "likely to amount to" was treated as requiring a tentative satisfaction at the notice stage, but that requirement was still not established. Section 297(2)(d)(ii) was therefore not construed as restoring an extinguished reopening power. en-us Wed, 07 Jan 1970 00:00:00 +0530 Thu, 19 Mar 2009 17:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7843 A reopening notice under the 1961 Act could not validly revive an assessment for 1949-50 where the power to reopen had already become barred under section 34 of the 1922 Act before the 1961 Act commenced. The old law permitted reopening after eight years only if escaped income had amounted to, or was likely to amount to, the prescribed threshold, and the materials did not show that condition. The phrase "likely to amount to" was treated as requiring a tentative satisfaction at the notice stage, but that requirement was still not established. Section 297(2)(d)(ii) was therefore not construed as restoring an extinguished reopening power. Case-Laws Income Tax Wed, 07 Jan 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7843