https://www.taxtmi.com/caselaws?id=27070 Reassessment under the Indian Income-tax Act, 1922 can be sustained only if the material actually before the Income-tax Officer at the time of initiation supports a bona fide belief that income had escaped assessment. Here, the record did not establish that the reasons memorandum or the relevant material was before the Income-tax Officer when sanction for reopening was sought, and the Court declined to accept a speculative reconstruction of that belief. On that basis, the reopening was treated as invalidly initiated, and the reference was answered against the Revenue on the reopening issue. en-us Wed, 07 Nov 1984 00:00:00 +0530 Sun, 08 May 2011 14:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27070 Reassessment under the Indian Income-tax Act, 1922 can be sustained only if the material actually before the Income-tax Officer at the time of initiation supports a bona fide belief that income had escaped assessment. Here, the record did not establish that the reasons memorandum or the relevant material was before the Income-tax Officer when sanction for reopening was sought, and the Court declined to accept a speculative reconstruction of that belief. On that basis, the reopening was treated as invalidly initiated, and the reference was answered against the Revenue on the reopening issue. Case-Laws Income Tax Wed, 07 Nov 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27070