Validity of reopening of Assessment If Assessing Officer failed to disclose the basis on which he formed the opinion that income chargeable to tax had escaped assessment

RELEVANT PARAGRAPH 3.  Before us Mr. O.S. Bajpai, the senior counsel appearing for the petitioners has vehemently contended that the notices in question are clearly misconceived and are simply for harassing the petitioners who are professionals.  The counsel has contended that the reasons which have been given for reopening of the assessment do not show that any new material has come to light for reopening of the assessment or that on the reasons stated there can be said to be that the officer had „reasons to believe for initiating reassessment. So far as the issue of incorrect valuation ...