Reassessment notices upheld where recorded reasons were relevant, sanction was endorsed, and no mere change of opinion was shown.

Reassessment notices under section 148 were upheld because the recorded reasons were found to be relevant and sufficiently connected to the Assessing Officer's belief that income had escaped assessment, including the exemption claims under sections 10(23A), 10(23C)(iv) and 11. The Court held that it only examines the existence and relevance of reasons, not their sufficiency, and rejected the objection based on alleged mechanical sanction under section 151(2) since the sanctioning authority had endorsed the recorded reasons. It also found no mere change of opinion because the earlier returns had been accepted without a speaking assessment order.

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Issues: Whether the reassessment notices issued under section 148 of the Income-tax Act, 1961, were valid in law, including on the grounds of absence of relevant reasons, change of opinion, and alleged mechanical sanction under section 151(2).

Analysis: The reasons recorded for reopening were held to be cogent and directly connected with the Assessing Officer's belief that income had escaped assessment, including the position regarding exemption claims under sections 10(23A), 10(23C)(iv), and 11. The Court held that it is not concerned with the sufficiency of the reasons, only with their existence and relevance. It further held that the sanctioning authority's endorsement that it agreed with the recorded reasons satisfied section 151(2), and the case did not involve a mere change of opinion because the earlier returns had been accepted without a speaking assessment order.

Conclusion: The reassessment notices were upheld as having been lawfully issued, and the challenge to them failed.

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