Court upholds validity of reassessment notices under Income Tax Act, emphasizing need for specific, reliable information.

The court upheld the validity of the reassessment notices issued under Section 148 of the Income Tax Act, 1961, finding that the reasons recorded for reopening the assessment were lawful and supported by tangible material. The court rejected the petitioner's argument that the reassessment was a mere change of opinion, emphasizing the importance of specific and reliable information for reassessment. As a result, all writ petitions challenging the reassessment notices were dismissed for lacking merit.

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Issues:
Challenge to re-assessment notices under Section 148 (1) of the Income Tax Act, 1961 and orders rejecting objections. Challenge to sanction under Section 151 of the Act. Proper reasons for re-assessment notice. True and full disclosure at the time of assessment. Legality of re-assessment notice and jurisdiction. Validity of reasons recorded under Section 151. Existence of tangible material for re-opening assessment. Maintainability of petitions after re-assessment. Jurisdiction of Assessment Officer. Validity of reassessment notice based on escaped income. Compliance with twin requirements for valid reassessment notice. Veracity of information supplied during regular assessment. Material for forming belief in reassessment. Legality and infirmity of notice under Section 148.

Analysis:
The petitioner challenged re-assessment notices under Section 148 (1) of the Income Tax Act, 1961, and orders rejecting objections, along with the sanction under Section 151. The argument was made that proper reasons for the re-assessment notice were lacking, as the income had not escaped assessment due to any undisclosed material facts. It was contended that the re-assessment was a change of opinion, impermissible in law, and the disposal of objections lacked proper reasoning.

The petitioner cited various legal precedents to support their argument, emphasizing the necessity of specific, reliable, and relevant information for reassessment. The Revenue, however, argued that the Principal CIT had recorded cogent reasons for re-opening the assessment, supported by tangible material, thus not constituting a change of opinion.

The Revenue further contended that the re-assessment proceedings had been completed, and the petitioner had the remedy of filing an appeal, making the present petitions non-maintainable. The jurisdiction of the Assessment Officer to determine if income had escaped assessment was highlighted, stating it could not be challenged in a writ petition.

Legal authorities were referenced by both parties, including decisions by the Supreme Court and various High Courts, to support their respective contentions. The Supreme Court's stance on the validity of reassessment notices and the importance of specific reasons for reassessment were discussed in detail.

The judgment concluded that the reasons recorded for the issuance of the notice under Section 148 did not suffer from any illegality or infirmity. It was held that the reassessment notice based on the belief that income had escaped assessment was lawful, and thus, all writ petitions were dismissed for lacking merit.

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