https://www.taxtmi.com/caselaws?id=59784 The Tribunal held that the reassessment proceedings initiated under Section 147(a) read with Section 148 were invalid due to the lack of a rational connection between the material and the formation of the belief by the ITO. The reassessment made by the ITO was vacated, and the appeal was allowed. The Tribunal also noted that similar cases cited by the Revenue were distinguishable on facts, as those cases involved specific confessions and direct nexus between the material and the formation of the belief, which were absent in the present case. en-us Wed, 11 Apr 1979 00:00:00 +0530 Sat, 01 Jan 2011 11:53:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59784 The Tribunal held that the reassessment proceedings initiated under Section 147(a) read with Section 148 were invalid due to the lack of a rational connection between the material and the formation of the belief by the ITO. The reassessment made by the ITO was vacated, and the appeal was allowed. The Tribunal also noted that similar cases cited by the Revenue were distinguishable on facts, as those cases involved specific confessions and direct nexus between the material and the formation of the belief, which were absent in the present case. Case-Laws Income Tax Wed, 11 Apr 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59784