https://www.taxtmi.com/caselaws?id=36894 The court held that the Income-tax Officer (ITO) lacked jurisdiction to issue notices under Section 148 as the prerequisites of Section 147(a) were not met. The reassessments were deemed invalid due to the lack of solid material supporting the belief of income escaping assessment. The court found no non-disclosure by the assessee and shifted the burden of proving the trust deed's non-genuineness to the ITO. Fresh material facts cited for reopening assessments were deemed irrelevant. Consequently, the court quashed the notices and reassessment orders, ruling in favor of the petitioners and against the reassessments made by the ITO. en-us Wed, 12 Sep 1979 00:00:00 +0530 Thu, 25 Mar 2010 12:18:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36894 The court held that the Income-tax Officer (ITO) lacked jurisdiction to issue notices under Section 148 as the prerequisites of Section 147(a) were not met. The reassessments were deemed invalid due to the lack of solid material supporting the belief of income escaping assessment. The court found no non-disclosure by the assessee and shifted the burden of proving the trust deed's non-genuineness to the ITO. Fresh material facts cited for reopening assessments were deemed irrelevant. Consequently, the court quashed the notices and reassessment orders, ruling in favor of the petitioners and against the reassessments made by the ITO. Case-Laws Income Tax Wed, 12 Sep 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36894