https://www.taxtmi.com/caselaws?id=39476 A notice under section 148 reopening assessment was upheld because the recorded reasons and subsequent confessional statements of two alleged lenders provided material rationally connected to a bona fide belief that alleged hundi loans were bogus and income had escaped assessment through non-disclosure of material facts. The Court held that, for section 147(a), it is concerned with the existence of relevant material and its rational nexus to the belief formed, not with the sufficiency or adequacy of that material. As some prima facie material existed, the reopening was valid and the challenge failed. en-us Wed, 26 Jun 1974 00:00:00 +0530 Fri, 16 Apr 2010 16:23:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39476 A notice under section 148 reopening assessment was upheld because the recorded reasons and subsequent confessional statements of two alleged lenders provided material rationally connected to a bona fide belief that alleged hundi loans were bogus and income had escaped assessment through non-disclosure of material facts. The Court held that, for section 147(a), it is concerned with the existence of relevant material and its rational nexus to the belief formed, not with the sufficiency or adequacy of that material. As some prima facie material existed, the reopening was valid and the challenge failed. Case-Laws Income Tax Wed, 26 Jun 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39476