Jurisdiction of AO to proceed with assessment under section 147 of IT Act, 1961

RELEVANT PARAGRAPH 22. In the present case, the notice u/s. 148 was issued on 28.03.2003, pertaining to the A.V. 1996-97. Section 147 authorizes and permit the Assessing Officers to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The scope of the expression “reason” in the phrase “reasons to believe” has been considered recently by the Hon’ble Supreme Court in the case of Asst. CIT vs. Rajesh Jhavery Stock Brokers Pvt. Ltd. (2007) 291 ITR 500 where the Hon’ble Supreme Court ...