https://www.taxtmi.com/caselaws?id=24541 Reopening of assessment fails where the Income-tax Officer does not independently form the requisite belief; a proposal made merely at the behest of superior authorities does not satisfy the jurisdictional condition, so the reassessment notice and ensuing proceedings were quashed. The challenge to service of notice was rejected because the assessee had later participated, sought recall, filed objections, and was given further opportunity, making the affixture-based service sufficient in the circumstances. The objection to approval for reopening also failed: the incorrect description of the assessee as a Hindu undivided family was treated as a technical defect, and the approving authority had applied its mind to the recorded reasons. en-us Fri, 23 Dec 1988 00:00:00 +0530 Tue, 28 Oct 2025 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24541 Reopening of assessment fails where the Income-tax Officer does not independently form the requisite belief; a proposal made merely at the behest of superior authorities does not satisfy the jurisdictional condition, so the reassessment notice and ensuing proceedings were quashed. The challenge to service of notice was rejected because the assessee had later participated, sought recall, filed objections, and was given further opportunity, making the affixture-based service sufficient in the circumstances. The objection to approval for reopening also failed: the incorrect description of the assessee as a Hindu undivided family was treated as a technical defect, and the approving authority had applied its mind to the recorded reasons. Case-Laws Income Tax Fri, 23 Dec 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24541