https://www.taxtmi.com/caselaws?id=22082 A jurisdictional objection to the initiation of reassessment under section 147(a) can be raised for the first time before the Appellate Assistant Commissioner, because the formation of belief that income has escaped assessment is a condition precedent to valid jurisdiction. Failure to object earlier does not waive a defect that goes to the root of the reassessment power. The first appellate authority's powers are coterminous with those of the Income-tax Officer, so it may entertain such a challenge even in a second round after remand. The Tribunal was therefore wrong to hold that the objection was barred. en-us Sat, 20 Apr 1991 00:00:00 +0530 Sat, 25 Oct 2025 12:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22082 A jurisdictional objection to the initiation of reassessment under section 147(a) can be raised for the first time before the Appellate Assistant Commissioner, because the formation of belief that income has escaped assessment is a condition precedent to valid jurisdiction. Failure to object earlier does not waive a defect that goes to the root of the reassessment power. The first appellate authority's powers are coterminous with those of the Income-tax Officer, so it may entertain such a challenge even in a second round after remand. The Tribunal was therefore wrong to hold that the objection was barred. Case-Laws Income Tax Sat, 20 Apr 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22082