Supreme Court Voids Tax Reassessment u/s 147 As Officer Failed To Prove Income Escaped Original Assessment.

HC quashed reassessment proceedings under s.147 initiated after four years. AO's reasons revealed information was derived from original assessment documents, indicating predecessor officer's incorrect assessment. Court found jurisdictional conditions under first proviso to s.147 unsatisfied. AO failed to adequately address petitioner's jurisdictional objections in rejection order, merely citing judgments without specific rebuttals. Though respondents later cited audit objections, these were not mentioned in original reasons or objection order. Court held reassessment notice under s.148 was without jurisdiction, illegal and arbitrary, as reopening must be tested solely on recorded reasons without subsequent additions. .....

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