https://www.taxtmi.com/caselaws?id=469072 Reassessment under sections 147 and 148 depends on recorded reasons that establish jurisdiction on a correct factual foundation. Where the reasons state that an assessee was a non-filer, but the record shows a return had in fact been filed under section 139, the foundational assumption is materially wrong and the belief of escapement cannot sustain reopening. The defect is not cured by the assessment order, and the reassessment is treated as void ab initio for want of valid jurisdiction. en-us Fri, 28 Mar 2025 00:00:00 +0530 Mon, 01 Jun 2026 15:12:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469072 Reassessment under sections 147 and 148 depends on recorded reasons that establish jurisdiction on a correct factual foundation. Where the reasons state that an assessee was a non-filer, but the record shows a return had in fact been filed under section 139, the foundational assumption is materially wrong and the belief of escapement cannot sustain reopening. The defect is not cured by the assessment order, and the reassessment is treated as void ab initio for want of valid jurisdiction. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469072