https://www.taxtmi.com/caselaws?id=21317 Reassessment under section 148 requires relevant material showing a bona fide reason to believe that income chargeable to tax escaped assessment for the specific year. Transactions from an earlier period, by themselves, could not support reopening for the relevant assessment year, and the amended definition of transfer under section 2(47) did not establish taxable capital gains in that year on the facts stated. Alleged notional interest on an advance was also outside section 147 because tax cannot be levied on income that neither accrued nor was received during the assessment year. In the absence of a nexus between the material and escapement of income in the relevant year, the reopening was without jurisdiction and was set aside. en-us Thu, 27 Aug 1992 00:00:00 +0530 Wed, 10 Dec 2025 22:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21317 Reassessment under section 148 requires relevant material showing a bona fide reason to believe that income chargeable to tax escaped assessment for the specific year. Transactions from an earlier period, by themselves, could not support reopening for the relevant assessment year, and the amended definition of transfer under section 2(47) did not establish taxable capital gains in that year on the facts stated. Alleged notional interest on an advance was also outside section 147 because tax cannot be levied on income that neither accrued nor was received during the assessment year. In the absence of a nexus between the material and escapement of income in the relevant year, the reopening was without jurisdiction and was set aside. Case-Laws Income Tax Thu, 27 Aug 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21317