https://www.taxtmi.com/caselaws?id=36318 Reassessment under sections 147(a) and 148 requires recorded reasons that themselves establish a bona fide belief of income escapement caused by the assessee's failure to make full and true disclosure of material facts. An informer's allegation, summons and non-compliance do not suffice where the reasons do not prima facie identify bogus transactions or non-disclosure, particularly when primary transaction facts were disclosed and examined in the original assessment. Later affidavits may clarify recorded reasons but cannot add new jurisdictional grounds. Section 297(2)(d)(ii) does not revive reassessment rights already time-barred under the repealed law; however, limitation did not independently invalidate the notice where the new Act's applicable time limit was met. The notice was quashed for failure of jurisdictional preconditions. en-us Fri, 18 Jan 1980 00:00:00 +0530 Sat, 20 Mar 2010 16:20:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36318 Reassessment under sections 147(a) and 148 requires recorded reasons that themselves establish a bona fide belief of income escapement caused by the assessee's failure to make full and true disclosure of material facts. An informer's allegation, summons and non-compliance do not suffice where the reasons do not prima facie identify bogus transactions or non-disclosure, particularly when primary transaction facts were disclosed and examined in the original assessment. Later affidavits may clarify recorded reasons but cannot add new jurisdictional grounds. Section 297(2)(d)(ii) does not revive reassessment rights already time-barred under the repealed law; however, limitation did not independently invalidate the notice where the new Act's applicable time limit was met. The notice was quashed for failure of jurisdictional preconditions. Case-Laws Income Tax Fri, 18 Jan 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36318