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of Reopening of assessment u/s 147 - reason to believe - new regime u/s 148A - The High Court held that, the amended provisions require a prima facie satisfaction of income escapement, not merely a 'reason to believe.' - Further, the impugned orders passed by the AO u/s 148A(d) of the Act are bad because, Petitioners’ Objections have not been considered. Thus, apart from being in violation of principles of natural justice, the assumption of jurisdiction under Sec. 148 is perverse and unsustainable. - Notice issued u/s 148 and order u/s 148A quashed.
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