https://www.taxtmi.com/caselaws?id=8097 Reopening beyond four years under section 147(1)(a) required the Income-tax Officer to have reason to believe that income escaped assessment because of the assessee's omission or failure to return income or to disclose fully and truly all material facts. The notices under section 148 were founded only on the earlier cancellation of the assessments under section 33B of the old Act, and no material was shown to establish any failure of disclosure in the original proceedings. The argument that returns filed before an officer lacking jurisdiction were a nullity was rejected as, at most, an irregularity. The statutory preconditions for reassessment were therefore not satisfied, and the notices were liable to be quashed. en-us Mon, 01 Dec 1969 00:00:00 +0530 Sat, 28 Mar 2009 12:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8097 Reopening beyond four years under section 147(1)(a) required the Income-tax Officer to have reason to believe that income escaped assessment because of the assessee's omission or failure to return income or to disclose fully and truly all material facts. The notices under section 148 were founded only on the earlier cancellation of the assessments under section 33B of the old Act, and no material was shown to establish any failure of disclosure in the original proceedings. The argument that returns filed before an officer lacking jurisdiction were a nullity was rejected as, at most, an irregularity. The statutory preconditions for reassessment were therefore not satisfied, and the notices were liable to be quashed. Case-Laws Income Tax Mon, 01 Dec 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8097