https://www.taxtmi.com/caselaws?id=60541 The Tribunal held that the challenge to reassessment reopening turned on appreciation of the record, including the absence of material supporting a bona fide belief of escaped income and the mechanical nature of administrative approval. As no irrelevant material was relied on and no relevant material was ignored, the existence of the statutory preconditions for reopening was treated as a question of fact rather than a question of law. The proposed reference questions therefore did not arise from the Tribunal's order, and the reference applications were not entertainable. The annulment of the reassessments remained undisturbed. en-us Mon, 20 Dec 1976 00:00:00 +0530 Wed, 05 Jan 2011 18:14:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60541 The Tribunal held that the challenge to reassessment reopening turned on appreciation of the record, including the absence of material supporting a bona fide belief of escaped income and the mechanical nature of administrative approval. As no irrelevant material was relied on and no relevant material was ignored, the existence of the statutory preconditions for reopening was treated as a question of fact rather than a question of law. The proposed reference questions therefore did not arise from the Tribunal's order, and the reference applications were not entertainable. The annulment of the reassessments remained undisturbed. Case-Laws Income Tax Mon, 20 Dec 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60541