https://www.taxtmi.com/caselaws?id=416003 Reopening of assessment under ss. 147/148 beyond four years was challenged on the ground that the AO lacked "reason to believe" and tangible material to support an addition under s. 69A. The HC held that the recorded reasons disclosed the tangible material forming the basis of belief of escapement, and at this stage the court should not stifle the AO's enquiry where statutory jurisdiction is being examined in reassessment proceedings. As the assessee had participated by furnishing details in response to notices under ss. 142(1) and 143(2) and had already raised objections before the AO, and an efficacious alternative statutory remedy existed, writ interference was declined and the impugned notice was allowed to proceed. en-us Wed, 08 Dec 2021 00:00:00 +0530 Fri, 26 Dec 2025 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416003 Reopening of assessment under ss. 147/148 beyond four years was challenged on the ground that the AO lacked "reason to believe" and tangible material to support an addition under s. 69A. The HC held that the recorded reasons disclosed the tangible material forming the basis of belief of escapement, and at this stage the court should not stifle the AO's enquiry where statutory jurisdiction is being examined in reassessment proceedings. As the assessee had participated by furnishing details in response to notices under ss. 142(1) and 143(2) and had already raised objections before the AO, and an efficacious alternative statutory remedy existed, writ interference was declined and the impugned notice was allowed to proceed. Case-Laws Income Tax Wed, 08 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416003