CENTRAL PROVINCES MANGANESE ORE. CO. LTD. vs I.T.O NAGPUR

The Supreme Court upheld the validity of the notice issued under Section 148 of the Income Tax Act, 1961, stating that the Income-Tax Officer had sufficient reason to believe that income had escaped assessment under Section 147(a). The Court clarified that reliance on findings from Customs Authorities regarding under-invoicing constituted valid grounds for reassessment. Furthermore, the appellant's failure to disclose material facts necessary for assessment satisfied the conditions for reassessment, leading to the dismissal of the appeal.