https://www.taxtmi.com/caselaws?id=10431 Reassessment notices under section 147 were quashed because the recorded reason rested on a misreading of an earlier ruling on deduction of cess on green tea leaves; the Court held that a genuine, legally tenable reason to believe was absent, showing non-application of mind. For notices issued beyond four years, the Court held that the proviso to section 147 required a specific allegation and factual basis of failure to disclose fully and truly all material facts, which was missing because the returns had disclosed the cess and the notices did not identify any suppression. The reassessment proceedings were therefore without jurisdiction. en-us Fri, 11 Mar 2005 00:00:00 +0530 Mon, 13 Jun 2011 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10431 Reassessment notices under section 147 were quashed because the recorded reason rested on a misreading of an earlier ruling on deduction of cess on green tea leaves; the Court held that a genuine, legally tenable reason to believe was absent, showing non-application of mind. For notices issued beyond four years, the Court held that the proviso to section 147 required a specific allegation and factual basis of failure to disclose fully and truly all material facts, which was missing because the returns had disclosed the cess and the notices did not identify any suppression. The reassessment proceedings were therefore without jurisdiction. Case-Laws Income Tax Fri, 11 Mar 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10431