In Assistant Commissioner of Income Tax v Rajesh Jhaveri Stock Brokers Pvt Ltd Civil Appeal No of the primary issue concerned the reopening of an income tax assessment under Section ... of the Income Tax Act The Assistant Commissioner issued a notice to Rajesh Jhaveri Stock Brokers Pvt Ltd under Section asserting that income had escaped assessment due to an incorrect understanding of the tax liability in a summary assessment under Section The company contested this reopening arguing that the original assessment was correctly made and there was no new material warranting reassessment