Conditions to reopen u/s. 147 after 4 years from end of relevant A.Y.

Notice issued u/s 148 after four year for reopening of assessment/s 147 on the ground that, in earlier assessment allowing depreciation on goodwill and set off of unabsorbed depreciation was erroneous. In terms of the proviso to Section 147of the said Act the jurisdiction to reopen assessments already completed under Section 143(3) of the said Act, after the period of four years from the end of the relevant assessment year can only be exercised on the cumulative satisfaction of two conditions precedent as under: 1. There must be a reasonable belief on the part of the officer that income has es...