In the result, both the appeals are disposed off in the terms indicated as above
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the circumstances under which income escaping assessment for the past assessment years could be assessed or reassessed. To confer jurisdiction under section 147(a) two conditions were required to be satisfied: firstly