https://www.taxtmi.com/caselaws?id=38061 An earlier final writ decision between the same parties on the foundational basis for reopening assessments barred re-agitation in later writ petitions under res judicata and constructive res judicata. The court held that the same material existing at the time of the earlier ruling could not be used again merely because different assessment years were involved, and the issue was decided for the assessee. It further held that notices under section 148 were invalid because the recorded reasons were vague, remote and lacked a live, rational nexus with a bona fide belief of escapement caused by failure to disclose primary facts fully and truly. The reassessment notices were quashed and costs were awarded to the assessee. en-us Tue, 24 Aug 1976 00:00:00 +0530 Sat, 03 Apr 2010 09:56:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38061 An earlier final writ decision between the same parties on the foundational basis for reopening assessments barred re-agitation in later writ petitions under res judicata and constructive res judicata. The court held that the same material existing at the time of the earlier ruling could not be used again merely because different assessment years were involved, and the issue was decided for the assessee. It further held that notices under section 148 were invalid because the recorded reasons were vague, remote and lacked a live, rational nexus with a bona fide belief of escapement caused by failure to disclose primary facts fully and truly. The reassessment notices were quashed and costs were awarded to the assessee. Case-Laws Income Tax Tue, 24 Aug 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38061