https://www.taxtmi.com/caselaws?id=22671 Reassessment notices issued after four years and beyond eight years were treated as distinct categories under the then-section 151: approval of the Commissioner applied to the former, while Board approval alone sufficed for the latter, with no cumulative approval requirement. A notice otherwise time-barred under section 147(b) could not be saved by section 150(1) read with Explanation 3 to section 153 unless the affected person had notice and an opportunity of hearing on the earlier finding or direction. Tribunal observations may nonetheless furnish sufficient material for the Assessing Officer's reason to believe under section 147(a), leaving the truth of the escaped-income allegation to reassessment proceedings. en-us Fri, 16 Nov 1990 00:00:00 +0530 Sat, 12 Dec 2009 11:57:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22671 Reassessment notices issued after four years and beyond eight years were treated as distinct categories under the then-section 151: approval of the Commissioner applied to the former, while Board approval alone sufficed for the latter, with no cumulative approval requirement. A notice otherwise time-barred under section 147(b) could not be saved by section 150(1) read with Explanation 3 to section 153 unless the affected person had notice and an opportunity of hearing on the earlier finding or direction. Tribunal observations may nonetheless furnish sufficient material for the Assessing Officer's reason to believe under section 147(a), leaving the truth of the escaped-income allegation to reassessment proceedings. Case-Laws Income Tax Fri, 16 Nov 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22671