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“reason to believe”

ReassessmentSection 147Section 1474,202 judgments

The decision most relied on for reason to believe is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on reason to believe

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

Judgments citing reason to believe

Shiv Vegpro Private Limited, Kota vs. PCIT-Udaipur, Udaipur

In the result, the appeal filed by the assessee is allowed

ITA 1014/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Jan 2025AY 2017-18
For Appellant: Shri Mahendra Gargieya, (Adv.) &For Respondent: Mrs. Alka Gautam, (CIT-DR)
Section 147Section 263Section 36(1)(iii)Section 36(1)(va)Section 43B

therefore, the AO, in the reassessment proceedings can assess only those item of income which have escaped assessment and find place in the reasons to believe but the income not being a part of the reasons recorded cannot be considered in the reassessment proceedings and also therefore, cannot be subject ... revision u/s 263 by the Ld. CIT. A Notice u/s 148 was issued on 17.03.2020 for A.Y. 2017-18 under consideration, and reasons to believe are recorded as communicated to the appellant by the AO vide his letter dt. 01.10.2020. For a ready reference the same are being reproduced hereunder

Ravi Mehra, 1121, Sector 10, Panchkula 134109, Haryana vs. Income Tax Officer, Ward-3, Panchkula, Haryana

In the result, the appeal of the assessee is allowed

ITA 189/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh28 Jan 2025AY 2012-2013

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(3)Section 147Section 148Section 151Section 68

Delhi has erred in holding the action of the Assessing Officer in reopening of the case u/s 148 and even there was no reason to believe that the income of the assessee has escaped assessment. 2. a) That the reopening have been sanctioned in a mechanical manner by the higher ... information received by the AO from the investigation wing via insight portal and without making any independent verifications, the Ld. AO formed reasons to believe that the amount received by the Assessee is merely layering of funds which is also evident from observation given by the AO in the disposal

Pratibha Vilas Patil, Mumbai vs. Nafc, Delhi

ITA 5537/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Jan 2025AY 2017-18

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. GopalFor Respondent: Shri Mahesh Pamnani
Section 144Section 147Section 69

merely placing reliance on the declaration made under the Income Declaration Scheme, 2016 is bad in law as there is no ‘reason to believe’ that any income chargeable to tax has escaped assessment. Hence, the notice issued under section 147 of the Act is unlawful, unsustainable

Kaatyaayini Steels Pvt Ltd, Mumbai vs. Income Tax Officer, WD-12(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 4398/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Jan 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am

For Appellant: Shri. Jay ThakkarFor Respondent: Shri. Hemanshu Joshi (Sr. DR)
Section 115BSection 142(1)Section 143(2)Section 145(3)Section 147Section 148Section 250Section 68

since had been issued in absence of fresh tangible material and on the basis of borrowed satisfaction and without having reason to believe of alleged escapement of income; 3.0 On facts and circumstances of the case and in law, Ld. CIT(A) ought to have deleted the addition u/s.68

Kaatyaayini Steels Pvt Ltd, Mumbai vs. Income Tax Officer, WD-12(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 4397/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Jan 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am

For Appellant: Shri. Jay ThakkarFor Respondent: Shri. Hemanshu Joshi (Sr. DR)
Section 115BSection 142(1)Section 143(2)Section 145(3)Section 147Section 148Section 250Section 68

since had been issued in absence of fresh tangible material and on the basis of borrowed satisfaction and without having reason to believe of alleged escapement of income; 3.0 On facts and circumstances of the case and in law, Ld. CIT(A) ought to have deleted the addition u/s.68

DCIT, Central Circle, Dehradun vs. R.B. Enterprises, Dehradun

ITA 4/DDN/2019[2010-11]Status: DisposedITAT Dehradun27 Jan 2025AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

Section 143(3)Section 147Section 148Section 153A(1)(b)

after obtaining the prior approval of Pr. CIT (Central), Kanpur on 29.03.2017. For reopening the assessment AO has recorded the reasons to believe, which is reproduced here-in-under: M/s R.B. Enterprises 7-Saharanpur Road, Dehra Dun PAN: AAGFR7892R Asstt. Year 2010-11 Reason for initiating action ... untaxed during the course of finalizing assessment order, in the year under consideration. 3 Keeping in view all the above facts, I have reason to believe that income chargeable to is tax amounting to Rs. 2,03,07,171/- for the A.Y. 2010-) has escaped assessment within the meaning

M/S. R.B. Enterprises, Dehradun vs. DCIT, Dehradun

ITA 3501/DEL/2017[2008-09]Status: DisposedITAT Dehradun27 Jan 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

Section 143(3)Section 147Section 148Section 153A(1)(b)

after obtaining the prior approval of Pr. CIT (Central), Kanpur on 29.03.2017. For reopening the assessment AO has recorded the reasons to believe, which is reproduced here-in-under: M/s R.B. Enterprises 7-Saharanpur Road, Dehra Dun PAN: AAGFR7892R Asstt. Year 2010-11 Reason for initiating action ... untaxed during the course of finalizing assessment order, in the year under consideration. 3 Keeping in view all the above facts, I have reason to believe that income chargeable to is tax amounting to Rs. 2,03,07,171/- for the A.Y. 2010-) has escaped assessment within the meaning

M/S. R.B. Enterprises, Dehradun vs. DCIT, Dehradun

ITA 3500/DEL/2017[2003-04]Status: DisposedITAT Dehradun27 Jan 2025AY 2003-04

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing)

Section 143(3)Section 147Section 148Section 153A(1)(b)

after obtaining the prior approval of Pr. CIT (Central), Kanpur on 29.03.2017. For reopening the assessment AO has recorded the reasons to believe, which is reproduced here-in-under: M/s R.B. Enterprises 7-Saharanpur Road, Dehra Dun PAN: AAGFR7892R Asstt. Year 2010-11 Reason for initiating action ... untaxed during the course of finalizing assessment order, in the year under consideration. 3 Keeping in view all the above facts, I have reason to believe that income chargeable to is tax amounting to Rs. 2,03,07,171/- for the A.Y. 2010-) has escaped assessment within the meaning

Jugal Chandra Saikia, Guwahati vs. Income Tax Officer, Ward-1(3), Guwahati

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 259/GTY/2018[1993-94]Status: DisposedITAT Guwahati27 Jan 2025AY 1993-94

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 143Section 250Section 254

sheet without any tangible material that income had escaped assessment. It makes the entire proceeding void ab initio, as the condition precedent i.e. reason to believe was absent, as recorded u/s 148(2) on 30/05/2001. 2.2 The assessment also suffers from perversity of facts and law and therefore without jurisdiction

Jugal Chandra Saikia, Guwahati vs. Income Tax Officer, Ward-1(3), Guwahati

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 258/GTY/2018[1992-93]Status: DisposedITAT Guwahati27 Jan 2025AY 1992-93

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 143Section 250Section 254

sheet without any tangible material that income had escaped assessment. It makes the entire proceeding void ab initio, as the condition precedent i.e. reason to believe was absent, as recorded u/s 148(2) on 30/05/2001. 2.2 The assessment also suffers from perversity of facts and law and therefore without jurisdiction

Manish Kumar Jaisinghani, Prabhat Plaza vs. Income Tax Officer 1(1) Indore, Indore

Appeal is allowed for statistical purpose

ITA 126/IND/2024[2015-2016]Status: DisposedITAT Indore27 Jan 2025AY 2015-2016

Bench: Shri B.M. Biyani & Shri Dinesh Mohan Sinha

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151

case and in law, the learned Assessing Officer erred in issuing a notice under section 148 of the Act without any reason to believe of his own and merely on the basis of information received from Investigation Wing and without independent application of mind which is neither legal nor proper

Muthurathinam, Tiruppur vs. ITO, Ward-1(2), Tiruppur

In the result, appeal filed by the assessee is allowed

ITA 2656/CHNY/2024[2013-14]Status: DisposedITAT Chennai27 Jan 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2656/Chny/2024 (िनधा"रणवष" / Assessment Year: 2013-2014) Muthurathinam, Vs. The Income Tax Officer, 27/29, Kumarappapuram, Ward 1(2) 1St Street, Rayapuram Extension, Tirupur. Tirupur 641 601. [Pan: Avypm 0862D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Sridhar, (Erode) Advocate By Virtual. ""यथ" क" ओर से /Respondent By : Ms. Anitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 31.12.2024 घोषणा क" तार"ख /Date Of Pronouncement : 27.01.2025 आदेश / O R D E R Per Manu Kumar Giri () This Penalty Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 21.08.2024 For Assessment Year 2013-14. 2. The Issue Sought To Be Urged By The Assessee In This Appeal Is Whether The Cit(A) Was Justified In Upholding The Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 ["Act"] By Ignoring The Fact That The Assessing Officer (‘Ao’ In Short) In Assessment Order Dated 28.09.2021 Has Satisfied That Penalty Proceeding Is Being Initiated Separately For “Furnishing Of Inaccurate Particulars Of Such Income” Where As Penalty Order U/S 271(1)(C) Dated 04.01.2022 Levied Penalty For “Concealment Of Income”, Although In The Notice Under Section 274 Read With Section 271(1) (C), The Ao Has Marked The Specified Limb As “That You Have Furnished Inaccurate Particulars Of Such Income”.

For Appellant: Shri. S. Sridhar, (Erode) Advocate by virtualFor Respondent: Ms. Anitha, IRS, Addl. CIT
Section 143(2)Section 143(3)Section 148Section 151Section 271Section 271(1)Section 271(1)(c)Section 274Section 44A

bank account during the FY 2012-13. In view of this, the assessing officer had a reason to believe that the income otherwise chargeable to tax has escaped assessment. Therefore, with the sanction of competent authority u/s 151 of the Act, a notice u/s 148 dated 28.02.2020 was issued

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1888/CHNY/2024[2017-18]Status: DisposedITAT Chennai27 Jan 2025AY 2017-18

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

notice u/s. 148, the re-assessment proceedings were carried out without any new finding "from materials upon which the respondent had reasons to believe" and proved to be a mere conduct of roving enquiry due to change of opinion as is evident from the nature of additions made ... Para-6:Basis of forming reason In view of the above findings, I have reasons to to believe and details of believe that reason to believe and income had escapement of income escaped assessment for the AY 2015-16 within the details of escapement of meaning of section

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1887/CHNY/2024[2016-17]Status: DisposedITAT Chennai27 Jan 2025AY 2016-17

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

notice u/s. 148, the re-assessment proceedings were carried out without any new finding "from materials upon which the respondent had reasons to believe" and proved to be a mere conduct of roving enquiry due to change of opinion as is evident from the nature of additions made ... Para-6:Basis of forming reason In view of the above findings, I have reasons to to believe and details of believe that reason to believe and income had escapement of income escaped assessment for the AY 2015-16 within the details of escapement of meaning of section

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1886/CHNY/2024[2015-16]Status: DisposedITAT Chennai27 Jan 2025AY 2015-16

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

notice u/s. 148, the re-assessment proceedings were carried out without any new finding "from materials upon which the respondent had reasons to believe" and proved to be a mere conduct of roving enquiry due to change of opinion as is evident from the nature of additions made ... Para-6:Basis of forming reason In view of the above findings, I have reasons to to believe and details of believe that reason to believe and income had escapement of income escaped assessment for the AY 2015-16 within the details of escapement of meaning of section

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1885/CHNY/2024[2014-15]Status: DisposedITAT Chennai27 Jan 2025AY 2014-15

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

notice u/s. 148, the re-assessment proceedings were carried out without any new finding "from materials upon which the respondent had reasons to believe" and proved to be a mere conduct of roving enquiry due to change of opinion as is evident from the nature of additions made ... Para-6:Basis of forming reason In view of the above findings, I have reasons to to believe and details of believe that reason to believe and income had escapement of income escaped assessment for the AY 2015-16 within the details of escapement of meaning of section

Hetalkumar Bhupendrabhai Joshi, Rajkot vs. ITO, Ward-2(2)(1), Rajkot

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 863/RJT/2024[2013-14]Status: DisposedITAT Rajkot24 Jan 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 861 & 863/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Hetalkumar Bhupendrabhai Joshi. Vs. The Ito, Ward-2(2)(1), Vijay Villa, C/O, Kankrai L Mehta, Rajkot. 5-Mahavir Society Nirmala Road, Rajkot-360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agspj0840P (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Raj Shekhar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 132Section 142(1)Section 147Section 148Section 250

case was reopened by issue of notice u/s 148 of the Income Tax Act. 1961 (hereinafter referred as Act) on 19.09.2019 with a reason to believe that the income for the A.Y. 2013-14 has escaped assessment within the meaning of provisions of section

Hetalkumar Bhupendrabhai Joshi, Rajkot vs. ITO, Ward-2(2)(1), Rajkot

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 861/RJT/2024[2013-14]Status: DisposedITAT Rajkot24 Jan 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 861 & 863/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Hetalkumar Bhupendrabhai Joshi. Vs. The Ito, Ward-2(2)(1), Vijay Villa, C/O, Kankrai L Mehta, Rajkot. 5-Mahavir Society Nirmala Road, Rajkot-360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agspj0840P (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Raj Shekhar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 132Section 142(1)Section 147Section 148Section 250

case was reopened by issue of notice u/s 148 of the Income Tax Act. 1961 (hereinafter referred as Act) on 19.09.2019 with a reason to believe that the income for the A.Y. 2013-14 has escaped assessment within the meaning of provisions of section

Rameshchand Badlani, Indore vs. ACIT 4 (1), Indore

The appeal of the assessee is allowed for statistical purpose

ITA 525/IND/2024[2014-15]Status: DisposedITAT Indore24 Jan 2025AY 2014-15

Bench: Shri B.M. Biyani & Shri Udayan Das Guptaassessment Year:2014-15 Rameshchand Badlani Acit 4(1) 43, Ananda Colony Indore बनाम/ Khajrana Road Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aehpb0735J Assessee By Shri Anil Kamal Garg, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 22.01.2025 Date Of Pronouncement 24.01.2025

Section 143(3)Section 147Section 250

confirming the action of the AO in framing the assessment and issuing the notice under s. 148 of the Act without having/recording any reason to believe that any chargeable income of the appellant for the assessment year under consideration had escaped to assessment. 4. That, without prejudice to the above ... issuance of the notice under s. 148 of the Act, merely on suspicion, without forming any objective satisfaction and without having tenable reasons to believe that any income had escaped to assessment in terms of the provisions of section 147 of the Act. 6. That, without prejudice to the above

Anjali Bhoomi Developers, Navi Mumbai vs. ITO, Ward-28(1)(1), Navi Mumbai

In the result, all the appeals of the assessee are allowed

ITA 1565/MUM/2024[2012-13]Status: DisposedITAT Mumbai24 Jan 2025AY 2012-13

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Ms. Ritika AgarwalFor Respondent: Shri Sunil Shinde, Sr.DR
Section 143(1)Section 143(3)Section 148

that the assessing officer did not entertain belief that there was escapement of income in these three years. In the absence of any reason to believe that there was escapement of income, we are of the view that the reopening of assessments of these three years