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    <title>1973 (7) TMI 12 - CALCUTTA High Court</title>
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    <description>Reopening under section 147(a) required the Income-tax Officer to hold, in good faith and on material with a rational connection to the belief, that income had escaped assessment. The recorded reasons referred generally to unsecured loans and alleged name-lending transactions, but the supporting material was not disclosed in the reasons or departmental affidavit, and the alleged statement was not shown to relate to the assessee or to have been before the officer when the notices were issued. The statutory condition precedent for jurisdiction was therefore not satisfied, and the reopening notices were invalid.</description>
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    <pubDate>Wed, 18 Jul 1973 00:00:00 +0530</pubDate>
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      <title>1973 (7) TMI 12 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=9117</link>
      <description>Reopening under section 147(a) required the Income-tax Officer to hold, in good faith and on material with a rational connection to the belief, that income had escaped assessment. The recorded reasons referred generally to unsecured loans and alleged name-lending transactions, but the supporting material was not disclosed in the reasons or departmental affidavit, and the alleged statement was not shown to relate to the assessee or to have been before the officer when the notices were issued. The statutory condition precedent for jurisdiction was therefore not satisfied, and the reopening notices were invalid.</description>
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      <pubDate>Wed, 18 Jul 1973 00:00:00 +0530</pubDate>
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