INDIAN OIL CORPORATION vs INCOME TAX OFFICER, CENTRAL CIRCLE V, CALCUTTA & ORS.

The Supreme Court addressed the conditions for reassessment under Section 147(1)(a) of the Income Tax Act, 1961, clarifying that the Income Tax Officer must have reason to believe that income has escaped assessment. The Court held that the assessee's failure to produce necessary auditors' certificates and relevant correspondence justified the reopening of assessments for the years 1957-58, 1958-59, and 1959-60. The earlier decision of the Single Judge was set aside, affirming the validity of the reassessment notices issued by the Revenue.