https://www.taxtmi.com/caselaws?id=21969 HC quashed notices issued u/s 147/148 for AYs 1970-71 to 1973-74, holding the AO lacked "reason to believe" that income had escaped assessment. The reopening was based solely on a Departmental Valuation Officer's report and an ipse dixit allocation of alleged excess construction cost across four years, without any rational, intelligible nexus to escapement for those specific years. HC reiterated that "reason to believe" requires objective, reasonable grounds, not vague or remote material, and that findings reached after due inquiry in earlier years cannot be disturbed absent fresh facts. The writ petitions were allowed and reassessment proceedings annulled. en-us Thu, 08 Nov 1990 00:00:00 +0530 Fri, 05 Dec 2025 19:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21969 HC quashed notices issued u/s 147/148 for AYs 1970-71 to 1973-74, holding the AO lacked "reason to believe" that income had escaped assessment. The reopening was based solely on a Departmental Valuation Officer's report and an ipse dixit allocation of alleged excess construction cost across four years, without any rational, intelligible nexus to escapement for those specific years. HC reiterated that "reason to believe" requires objective, reasonable grounds, not vague or remote material, and that findings reached after due inquiry in earlier years cannot be disturbed absent fresh facts. The writ petitions were allowed and reassessment proceedings annulled. Case-Laws Income Tax Thu, 08 Nov 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21969