https://www.taxtmi.com/caselaws?id=276947 Under Section 34 of the Indian Income-tax Act, 1922, the Court in writ jurisdiction would not test the adequacy of the material if the Income-tax Officer honestly formed the requisite "reason to believe"; the preliminary satisfaction was treated as a jurisdictional matter, and any error lay in the statutory appellate process. The amended Section 34, introduced in 1948, was held not to apply retrospectively to earlier assessment years because it enlarged reassessment liability and curtailed assessee protection, which could not be imposed without clear legislative language. The reassessment notices under the amended provision were therefore beyond jurisdiction and prohibition was warranted. en-us Wed, 26 Mar 1952 00:00:00 +0530 Tue, 20 Nov 2018 17:06:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276947 Under Section 34 of the Indian Income-tax Act, 1922, the Court in writ jurisdiction would not test the adequacy of the material if the Income-tax Officer honestly formed the requisite "reason to believe"; the preliminary satisfaction was treated as a jurisdictional matter, and any error lay in the statutory appellate process. The amended Section 34, introduced in 1948, was held not to apply retrospectively to earlier assessment years because it enlarged reassessment liability and curtailed assessee protection, which could not be imposed without clear legislative language. The reassessment notices under the amended provision were therefore beyond jurisdiction and prohibition was warranted. Case-Laws Income Tax Wed, 26 Mar 1952 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276947