https://www.taxtmi.com/caselaws?id=751530 Reassessment under sections 147 and 148 requires tangible material giving the Assessing Officer reason to believe that income has escaped assessment; the belief cannot rest on vague or conjectural material. An expert commission report, without independent application of mind or concrete evidence of actual escapement, is insufficient. Here, the report only suggested a lower declared export price than the prevailing international price and did not show receipt of consideration over and above invoice value. The reassessment notice and all consequential proceedings were therefore without jurisdiction and could not be sustained. en-us Fri, 05 Apr 2024 00:00:00 +0530 Fri, 12 Jun 2026 09:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751530 Reassessment under sections 147 and 148 requires tangible material giving the Assessing Officer reason to believe that income has escaped assessment; the belief cannot rest on vague or conjectural material. An expert commission report, without independent application of mind or concrete evidence of actual escapement, is insufficient. Here, the report only suggested a lower declared export price than the prevailing international price and did not show receipt of consideration over and above invoice value. The reassessment notice and all consequential proceedings were therefore without jurisdiction and could not be sustained. Case-Laws Income Tax Fri, 05 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751530