1985 (7) TMI 73

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....tions is concerned with the validity of notices under section 147(a) read with section 148 of the Income-tax Act, 1961, relating to several years. We had issued a show-cause notice. The case of the petitioner is that there was no material or reasons at all for reopening the assessment for those years. In reply, the case of the Department is that during some other proceedings in Bombay, it was disc....

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.... assessment is circumscribed by the conditions laid down in section 147(a). Certain facts have to exist to show that an assessment can be reopened. The existence of such reasons and a direct nexus between those reasons and the alleged evasion is a condition precedent for reopening the assessment. However, in a case like the present, where there are disputed facts, it is not easy to ascertain what ....