Reopening under Section 148 based on materially similar reasons was quashed, with all consequential reassessment orders set aside.

Reopening under the Income-tax Act based on materially similar recorded reasons was found unsustainable where those reasons had already been held invalid in a connected matter decided the same day. The Bombay HC applied the earlier view to the present petitions and quashed the Section 148 notices, the consequential assessment order, and all related orders. As the reassessment proceedings rested on the impugned reopening, they were invalidated in full.

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Issues: Whether the notices and orders initiating reopening under Section 148 of the Income-tax Act, 1961, along with the consequential assessment and related orders, were liable to be quashed.

Analysis: The reasons recorded for reopening in these petitions were stated to be substantially similar to those considered in an earlier matter decided on the same day, and the Revenue did not dispute that position. The Court, therefore, applied the view already expressed in the connected matter to the present petitions.

Conclusion: The impugned notices and orders were quashed and set aside, along with all consequential notices, assessment order and consequential orders, if any.

Final Conclusion: The writ petitions succeeded and the reassessment proceedings founded on the impugned reopening were invalidated.

Ratio Decidendi: Where the recorded reasons for reopening are materially the same as those already found unsustainable in a connected case, the impugned reassessment notices and all consequential orders cannot be sustained.

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