Re-opening of assessment.

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....e deemed to have escaped assessment in the following cases, namely:—      (a) where the tax base for the relevant financial year exceeds the maximum amount not liable to tax but        (i) the return of tax bases has not been furnished;        (ii) no notice has been issued under section 146; and        (iii) the time limitation for issuing such notice has expired;      (b) where a return of tax bases has been furnished by the assessee, but-         (i) no assessment has been made; and         (ii) the assessee has unders....

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....e commencement of this Code or this Code and such objection forms part of the report of the Comptroller and Auditor General of India laid before each House of Parliament;     (d) where search and seizure has been carried out under section 135, or material has been obtained in pursuance of a requisition under section 136, in the case of the person;     (e) where any material which has been seized, or obtained in pursuance of a requisition, has a bearing on the determination of the tax bases of a person other than the person referred to in clause (d).   (4) The notice under sub-section (2) shall be issued—      (a) for the seven financial years immediately preceding the fina....

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.... is a fit case for issue of such notice;         (ii) after the expiry of a period of four years from the end of the relevant financial year, unless the Commissioner is so satisfied;      (b) in any other case, by an Assessing Officer below the rank of Joint Commissioner after the expiry of a period of four years from the end of the relevant financial year, unless the Joint Commissioner is satisfied on the reasons recorded by such Assessing Officer that it is a fit case for issue of such notice.   (7) The Commissioner or the Joint Commissioner, being satisfied on the reasons recorded by the Assessing Officer regarding fitness of a case for the issue of notice under this se....

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....ed had the tax bases not escaped assessment.   (12) The proceedings under this section, excluding the proceedings initiated in consequence of the condition specified in clauses (d) and (e) of sub-section (3) shall be dropped, if—      (a) the assessee has not impugned any part of the original assessment order for the relevant financial year under sections 178 and 192;      (b) he establishes that he had been assessed on an amount not lower than what he would be rightly liable for, even if the tax base alleged to have escaped assessment had been taken into account; and      (c) the original assessment order has not been revised under section 161 or section 191. ....