https://www.taxtmi.com/caselaws?id=58286 The tribunal held that reassessment under section 147(a) of the Income-tax Act was not permissible in this case due to lack of reasonable grounds for believing in non-disclosure of material facts by the assessee. Although reassessment under section 147(b) was deemed possible, it was time-barred. Consequently, the reassessments for the relevant years were annulled, and the assessee's appeals were upheld. The judgment emphasizes the necessity of a valid and rational basis for reopening assessments, cautioning against relying on mere suspicion without substantial evidence of non-disclosure by the assessee. en-us Mon, 18 Jul 1988 00:00:00 +0530 Sat, 18 Dec 2010 13:04:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58286 The tribunal held that reassessment under section 147(a) of the Income-tax Act was not permissible in this case due to lack of reasonable grounds for believing in non-disclosure of material facts by the assessee. Although reassessment under section 147(b) was deemed possible, it was time-barred. Consequently, the reassessments for the relevant years were annulled, and the assessee's appeals were upheld. The judgment emphasizes the necessity of a valid and rational basis for reopening assessments, cautioning against relying on mere suspicion without substantial evidence of non-disclosure by the assessee. Case-Laws Income Tax Mon, 18 Jul 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58286