Sec. 147 Reopening assessment for Verification of certain details not valid

Clear language of section 147 of the IT Act reveals that if the Assessing Officer has reason to believe that any income has escaped assessment, then, he can resort to such power. While it is true, as Mr. Gupta argued, that sub­section (1) of section 148 of the IT Act enables issuance of notice before the assessment, reassessment or re­computation under section 147 of the IT Act, but that is dealing with the service of the notice. The principal condition for issuance of notice is to be found in section 147 of the IT Act and that is on the reason to belief that any income chargeable to tax

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