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Section 147 of the Income-tax Act, 1961 - Income escaping assessment - Non-disclosure of primary facts - Assessment year 1994-95 - Assessee had originally filed return declaring an income of Rs. 34,800 and assessment had been made accepting said return - Subsequently, in September 1998, Assessing Officer received information from Assistant Commissioner, that though assessee had filed a declaration under VDIS, 1997 disclosing income of Rs. 2 lakhs in form of cash for relevant assessment year, he had not paid due tax and, therefore, said declaration was deemed not to have been filed as per provisions of VDIS - On basis of that information, Assessing Officer initiated reassessment proceedings and framed a fresh assessment - Whether, on facts, reassessment proceedings initiated by Assessing Officer were justified - Held, yes Section 148 of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment year 1994-95 - Whether there is no requirement of serving notice on assessee personally - Held, yes CASE REVIEW CIT v. Hotline International (P.) Ltd. [2007] 161 Taxman 104 (Delhi) distinguished [Para 8]. CASE REFERRED TO CIT v. Hotline International (P.) Ltd. [2007] 161 Taxman 104 (Delhi) [Para 7]. Ms. Radhika Suri for the Appellant. Vivek Sethi for the Respondent. ORDER Ajay Tewari, J. - This order shall dispose of I.T.A Nos. 484 and 485 of 2007, as common questions of law and facts are involved therein. For the sake of convenience, facts are being extracted from I.T.A No. 484 of 2007. 2. This appeal filed by the assessee proposes the following questions of law:- "(i)Whether in the facts and circumstances of the case the notice under section 148 of the Income-tax Act was validly served on the assessee? (ii)Whether in facts and circumstances of the case the appellant was prevented by sufficient cause from appearing before the Assessing Officer and, therefore, the ex parte assessment under section 144 was liable to be set aside. (iii)Whether in the facts and circumstances of the case the Assessing Officer could invoke the jurisdiction to initiate the reassessment proceedings under section 147 of the Income-tax Act on the basis of the VDIS…

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