Sec. 147 of Income Tax Act, 1961— Reassessment - The petitioner assailed the legality and validity of the four impugned noticesissued under Section 148 of the Act, 1961 proposing to re-assess the income of the petitioner for the four assessment years on the ground that income chargeable to tax for the said assessment years had escaped assessment within the meaning of Section 147 of the Act. Writ petition came to be allowed by holding that “it is quite evident that there was no basis or justification for respondent No.1 to form a belief that any income of the assesee chargeable to tax for the assessment years under consideration had escaped assessment within the meaning of Section 147 of the Act. The reasons rendered could not have led to formation of any belief that income had escaped assessment within the meaning of the aforesaid provision. - J.S. & M.F. BUILDERS V/s A.K. CHAUHAN - [2020] 272 TAXMAN 359 (BOM)