https://www.taxtmi.com/caselaws?id=23913 A notice for reopening assessment under sections 147/148 is a jurisdictional notice, and conditions precedent such as existence of reasons, application of mind, recording of reasons and endorsement must be satisfied. Here, the petitioner did not raise those objections in reply to the show-cause notice or secure a finding from the assessing authority. The Allahabad HC held that such objections could still be raised in appeal and, because an efficacious alternative remedy was available, the writ petition for quashing the reopening notices was not maintainable. The court left the merits of alleged jurisdictional defects, arbitrariness and denial of opportunity open for the appellate forum. en-us Wed, 26 Apr 1989 00:00:00 +0530 Fri, 15 Jan 2010 12:19:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=23913 A notice for reopening assessment under sections 147/148 is a jurisdictional notice, and conditions precedent such as existence of reasons, application of mind, recording of reasons and endorsement must be satisfied. Here, the petitioner did not raise those objections in reply to the show-cause notice or secure a finding from the assessing authority. The Allahabad HC held that such objections could still be raised in appeal and, because an efficacious alternative remedy was available, the writ petition for quashing the reopening notices was not maintainable. The court left the merits of alleged jurisdictional defects, arbitrariness and denial of opportunity open for the appellate forum. Case-Laws Income Tax Wed, 26 Apr 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=23913