https://www.taxtmi.com/caselaws?id=755513 Reopening of assessment under Section 147/148 requires recorded reasons showing a jurisdictional belief that income has escaped assessment, supported by material and not merely suspicion. The text distinguishes a genuine "reason to believe" from a "reason to suspect" and notes that failure to disclose truly and fully all material facts remains the jurisdictional prerequisite. It also states that an additional jurisdictional ground may be admitted at the appellate stage where no new facts are required, and that a correctable mistake does not alter the tenor of proceedings under Section 292B. The accompanying special leave petition is described as having been filed with gross delay. en-us Thu, 11 Jul 2024 00:00:00 +0530 Thu, 30 Jul 2026 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755513 Reopening of assessment under Section 147/148 requires recorded reasons showing a jurisdictional belief that income has escaped assessment, supported by material and not merely suspicion. The text distinguishes a genuine "reason to believe" from a "reason to suspect" and notes that failure to disclose truly and fully all material facts remains the jurisdictional prerequisite. It also states that an additional jurisdictional ground may be admitted at the appellate stage where no new facts are required, and that a correctable mistake does not alter the tenor of proceedings under Section 292B. The accompanying special leave petition is described as having been filed with gross delay. Case-Laws Income Tax Thu, 11 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755513