https://www.taxtmi.com/caselaws?id=76496 HC set aside the notice issued under section 148, holding reassessment was invalid where no new or fresh material existed to justify formation of belief that income had escaped assessment. The court found the earlier section 154 rectification proceedings had been dropped after the AO concluded no apparent error on the record, and the subsequent reopening amounted to a mere change of opinion. Absent any material different from that already considered, the AO lacked jurisdiction to reopen assessment. Writ petition disposed and the impugned section 148 notice quashed. en-us Fri, 28 Aug 2009 00:00:00 +0530 Thu, 13 Nov 2025 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=76496 HC set aside the notice issued under section 148, holding reassessment was invalid where no new or fresh material existed to justify formation of belief that income had escaped assessment. The court found the earlier section 154 rectification proceedings had been dropped after the AO concluded no apparent error on the record, and the subsequent reopening amounted to a mere change of opinion. Absent any material different from that already considered, the AO lacked jurisdiction to reopen assessment. Writ petition disposed and the impugned section 148 notice quashed. Case-Laws Income Tax Fri, 28 Aug 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=76496