https://www.taxtmi.com/caselaws?id=354765 Reassessment under sections 147 and 148 is valid only where the Assessing Officer's recorded reasons clearly and unambiguously show a real reason to believe that income chargeable to tax has escaped assessment. Those reasons must stand on their own and cannot be improved, substituted, or supplemented by later explanations or oral submissions. On the facts, the recorded reasons were based on conjecture and did not disclose tangible material establishing escapement of income, so the reopening lacked jurisdiction. The reassessment proceedings were therefore quashed, and the Revenue's appeals failed. en-us Tue, 16 Jan 2018 00:00:00 +0530 Sat, 03 Feb 2018 08:35:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354765 Reassessment under sections 147 and 148 is valid only where the Assessing Officer's recorded reasons clearly and unambiguously show a real reason to believe that income chargeable to tax has escaped assessment. Those reasons must stand on their own and cannot be improved, substituted, or supplemented by later explanations or oral submissions. On the facts, the recorded reasons were based on conjecture and did not disclose tangible material establishing escapement of income, so the reopening lacked jurisdiction. The reassessment proceedings were therefore quashed, and the Revenue's appeals failed. Case-Laws Income Tax Tue, 16 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354765