Finality of assessment: reassessment cannot proceed on identical material; notices based on same record are void.

Reassessment of bank-deposit transactions already examined and finally adjudicated in a completed assessment cannot be initiated on the same material absent fresh, independent tangible material giving rise to reasons to believe; mere change of opinion or re-examination is impermissible. Consequently, notices and proceedings seeking reassessment which rely on identical material as the original assessment are invalid and liable to be quashed, and alternative statutory remedies do not preclude relief where finality of assessment and protection against vexatious double taxation are engaged.

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Issues: Whether the Deputy Commissioner of Income Tax (DCIT) was competent to initiate reassessment proceedings under Section 147 by issuing notice under Section 148 in 2025 in respect of the same bank-deposit transactions which had already been investigated and finally adjudicated by the Income Tax Officer (ITO) in assessment order dated 30.03.2023 for Assessment Year 2019-20.

Analysis: The Court examined the record and found the self-same cash-deposit transactions with Canara Bank (total Rs. 4,42,47,290/-) had been subject-matter of proceedings before the ITO, who on verification of audited accounts, bank statements and returns filed under PAN-2 had concluded assessment for the relevant year and assessed total income at nil. The DCIT's subsequent Order under Section 148A(3) and notice under Section 148 relied on the same material and sought reassessment without any showing that the ITO's order had been varied, reversed or that fresh and distinct material existed. The Court applied settled principles that reassessment proceedings cannot be a mere re-examination or review of a concluded assessment on a mere change of opinion; the initiation of reassessment requires independent tangible material giving rise to 'reasons to believe' and completed assessments attain finality and cannot be reopened for the same subject-matter, as doing so would amount to vexation twice for the same cause and risk double taxation. The Court further found no dispute on facts and held that alternative statutory remedies did not oust the High Court's jurisdiction to grant relief in this factual matrix.

Conclusion: The Order dated 24.06.2025 under Section 148A(3), Notice dated 30.06.2025 under Section 148 and intimation dated 25.07.2025 under Section 144B issued by the DCIT insofar as they seek reassessment of the same transactions already finally adjudicated by the ITO are quashed and set aside; the writ petition is allowed in favour of the assessee.

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