https://www.taxtmi.com/caselaws?id=16659 The dominant issue was whether reassessment reopening under s.147/s.148 was vitiated for lack of "reason to believe" and amounted to a roving enquiry. The HC held that, in writ jurisdiction, it cannot examine the sufficiency of material and only tests whether the material is relevant and has a rational connection or live link to the belief of escapement. Information arising from a search of a locker jointly held with the spouse, revealing cash and jewellery, and the investigation communication and appraisal report constituted relevant material; it could not be said the AO lacked the requisite belief. The challenge to the s.148 notice failed and the writ petition was dismissed. en-us Thu, 28 May 1998 00:00:00 +0530 Wed, 31 Dec 2025 18:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16659 The dominant issue was whether reassessment reopening under s.147/s.148 was vitiated for lack of "reason to believe" and amounted to a roving enquiry. The HC held that, in writ jurisdiction, it cannot examine the sufficiency of material and only tests whether the material is relevant and has a rational connection or live link to the belief of escapement. Information arising from a search of a locker jointly held with the spouse, revealing cash and jewellery, and the investigation communication and appraisal report constituted relevant material; it could not be said the AO lacked the requisite belief. The challenge to the s.148 notice failed and the writ petition was dismissed. Case-Laws Income Tax Thu, 28 May 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16659