https://www.taxtmi.com/caselaws?id=8506 Reassessment under the escaped-income provisions was unsustainable because the reopening lacked relevant material to form the required belief of nondisclosure, and the alternative basis was time-barred; the notice under section 148 was therefore invalid. The commentary also notes that a saving or machinery provision cannot create a fresh tax liability unless the amount is otherwise chargeable under the charging provisions, so the sum could not be taxed under section 28(ii)(c) or section 41(1). It further explains that the amount did not fall within the 1922 Act provisions on agency termination compensation or remission of trading liability, so no taxability arose on that basis either. en-us Wed, 22 Sep 1971 00:00:00 +0530 Mon, 27 Apr 2009 17:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8506 Reassessment under the escaped-income provisions was unsustainable because the reopening lacked relevant material to form the required belief of nondisclosure, and the alternative basis was time-barred; the notice under section 148 was therefore invalid. The commentary also notes that a saving or machinery provision cannot create a fresh tax liability unless the amount is otherwise chargeable under the charging provisions, so the sum could not be taxed under section 28(ii)(c) or section 41(1). It further explains that the amount did not fall within the 1922 Act provisions on agency termination compensation or remission of trading liability, so no taxability arose on that basis either. Case-Laws Income Tax Wed, 22 Sep 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8506