https://www.taxtmi.com/caselaws?id=17008 Reopening under s.147/s.148 was challenged as lacking the condition precedent of "reason to believe" and absence of failure to disclose fully and truly all material facts. The HC held that assumption of jurisdiction under s.147 must rest on real, tangible material and a rational nexus between such material and the belief of escapement, reflecting application of mind; however, in writ jurisdiction under Art. 226, the court cannot test the sufficiency or adequacy of the material if prima facie material exists. As the assessment was reopened on returns and an alleged disclosure failure, and the objections were considered, the notices were upheld and the writ petitions were dismissed. en-us Thu, 19 Feb 1998 00:00:00 +0530 Tue, 30 Dec 2025 18:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17008 Reopening under s.147/s.148 was challenged as lacking the condition precedent of "reason to believe" and absence of failure to disclose fully and truly all material facts. The HC held that assumption of jurisdiction under s.147 must rest on real, tangible material and a rational nexus between such material and the belief of escapement, reflecting application of mind; however, in writ jurisdiction under Art. 226, the court cannot test the sufficiency or adequacy of the material if prima facie material exists. As the assessment was reopened on returns and an alleged disclosure failure, and the objections were considered, the notices were upheld and the writ petitions were dismissed. Case-Laws Income Tax Thu, 19 Feb 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17008