https://www.taxtmi.com/caselaws?id=76871 HC allowed the petition, holding the s.148 notice invalid because the Assessing Officer lacked tangible material to form a reason to believe that income had escaped assessment under s.147. The court found the reassessment amounted to an impermissible change of opinion concerning deductions for tank land liability and disallowance of depreciation on written-off obsolete assets. The original computation, accepting deductions of Rs. 3.16 crores, stood and the reasons for reopening did not substantively address the issues; accordingly the reopening was quashed. en-us Mon, 08 Mar 2010 00:00:00 +0530 Mon, 17 Nov 2025 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=76871 HC allowed the petition, holding the s.148 notice invalid because the Assessing Officer lacked tangible material to form a reason to believe that income had escaped assessment under s.147. The court found the reassessment amounted to an impermissible change of opinion concerning deductions for tank land liability and disallowance of depreciation on written-off obsolete assets. The original computation, accepting deductions of Rs. 3.16 crores, stood and the reasons for reopening did not substantively address the issues; accordingly the reopening was quashed. Case-Laws Income Tax Mon, 08 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=76871