https://www.taxtmi.com/caselaws?id=21379 Recorded reasons were found sufficient to support jurisdiction for issuance of notice under section 148, so the reassessment notice was upheld. The objection that prior notice under section 163(2) was a precondition to reassessment was not accepted on the facts, because the assessee had filed the return as a representative assessee and had taken the position that the foreign collaborator's payment was not taxable. That contention was left open only for response to the show-cause notice, but it did not defeat the reassessment proceedings. en-us Fri, 24 Jul 1992 00:00:00 +0530 Sat, 21 Nov 2009 18:45:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21379 Recorded reasons were found sufficient to support jurisdiction for issuance of notice under section 148, so the reassessment notice was upheld. The objection that prior notice under section 163(2) was a precondition to reassessment was not accepted on the facts, because the assessee had filed the return as a representative assessee and had taken the position that the foreign collaborator's payment was not taxable. That contention was left open only for response to the show-cause notice, but it did not defeat the reassessment proceedings. Case-Laws Income Tax Fri, 24 Jul 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21379