Finality of assessment bars reopening on same search material; section 148 notice was invalid and reassessment was quashed.

Reassessment under section 147(a) read with section 148 was impermissible where the proposed reopening rested on the same search material and assessment history that had already been examined in completed appellate and tribunal proceedings. Because the Tribunal had dealt with the assessment and the matter had attained finality, reopening on a fresh appraisal of the same material amounted to an attempt at piecemeal reassessment beyond the assessing authority's jurisdiction. The notice under section 148 was therefore invalid and the reassessment proceedings were quashed.

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Issues: Whether reassessment proceedings initiated under section 147(a) read with section 148 of the Income-tax Act, 1961 were valid after the assessment had already been the subject of completed appellate and tribunal proceedings on the same material.

Analysis: The reasons recorded for issuance of notice showed that the proposed reassessment was founded on the same search material and earlier assessment history. The Tribunal had already dealt with the assessment and the order had attained finality. On that basis, the attempt to reopen the matter was treated as contrary to the principle of finality and as an impermissible attempt to reassess piecemeal on a fresh appraisal of material already available from the search. The reopening was held to exceed the assessing authority's jurisdiction.

Conclusion: The notice issued under section 148 was invalid and the reassessment proceedings were quashed.

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