Reassessment notice under section 148 need not specify escaped income details at issuance when statutory requirements are satisfied.

At the stage of issuing a reassessment notice under section 148, the assessing authority need not disclose the specific item or source of escaped income. Where the statutory preconditions are met, including compliance with section 148 and prior sanction under section 151, a writ court will not interfere merely because the assessee alleges a change of opinion. Those objections may be raised before the Income-tax Officer in the reassessment proceedings. The notice was therefore not quashed, and the challenge to reopening failed.

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Issues: Whether the notice issued for reopening of assessment under section 148 was liable to be interfered with at the writ stage, including the contention that it was based on a mere change of opinion and that reasons need not be furnished before reassessment proceedings.

Analysis: The assessment had already been completed for the relevant year, and the Income-tax Officer issued notice on the basis of escapement of income. The Court held that, at the stage of issuance of notice, it was not necessary to specify the exact item of escaped income or the source of such income. The assessee could raise the plea of change of opinion and other objections before the Income-tax Officer in the reassessment proceedings. The Court also noted that the jurisdictional requirement under section 148 had been complied with and that sanction under section 151 had been obtained.

Conclusion: The notice under section 148 was not liable to be quashed at this stage, and the writ petition was without merit.

Final Conclusion: Interference with the reopening notice was declined, and the challenge to the reassessment proceedings failed.

Ratio Decidendi: At the stage of issuance of a reassessment notice, the assessing authority need not disclose the specific item or source of escaped income, and a writ court will not interfere where the statutory preconditions, including sanction where required, have been satisfied.

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