https://www.taxtmi.com/caselaws?id=11012 The HC held the notice issued under s.148 invalid and quashed it, finding the Assessing Officer lacked jurisdiction. While s.147 permits reassessment where income has escaped, the proviso bars action after four years unless the assessee failed to file a return or to truly and fully disclose material facts. The AO's reasons only recorded escapement of income (excess relief under s.80-O) and contained no finding of failure to disclose; absence of that requisite finding rendered initiation of proceedings after four years without jurisdiction. en-us Sat, 20 Dec 2003 00:00:00 +0530 Wed, 24 Sep 2025 18:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11012 The HC held the notice issued under s.148 invalid and quashed it, finding the Assessing Officer lacked jurisdiction. While s.147 permits reassessment where income has escaped, the proviso bars action after four years unless the assessee failed to file a return or to truly and fully disclose material facts. The AO's reasons only recorded escapement of income (excess relief under s.80-O) and contained no finding of failure to disclose; absence of that requisite finding rendered initiation of proceedings after four years without jurisdiction. Case-Laws Income Tax Sat, 20 Dec 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11012