https://www.taxtmi.com/caselaws?id=465428 Reopening under s.147 (as applicable prior to 01.04.1989) was upheld on the ground that the assessee omitted to file a return u/s 139 and failed to disclose material facts, giving the AO "reason to believe" that income had escaped assessment. The AO relied on entries in a seized loose sheet (KS-19); despite notice and questionnaire, the assessee gave no explanation for the relevant year and only later attributed the account to a parent, which did not negate reliance on the document. The HC held that the Evidence Act was inapplicable and natural justice was satisfied by affording opportunity. The reassessment and Tribunal's order were sustained and the appeal was dismissed. en-us Mon, 20 Jun 2016 00:00:00 +0530 Sat, 20 Dec 2025 13:32:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465428 Reopening under s.147 (as applicable prior to 01.04.1989) was upheld on the ground that the assessee omitted to file a return u/s 139 and failed to disclose material facts, giving the AO "reason to believe" that income had escaped assessment. The AO relied on entries in a seized loose sheet (KS-19); despite notice and questionnaire, the assessee gave no explanation for the relevant year and only later attributed the account to a parent, which did not negate reliance on the document. The HC held that the Evidence Act was inapplicable and natural justice was satisfied by affording opportunity. The reassessment and Tribunal's order were sustained and the appeal was dismissed. Case-Laws Income Tax Mon, 20 Jun 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465428