https://www.taxtmi.com/caselaws?id=203601 HC allowed the appeal, holding that issuance of notice under s.148 set aside the earlier assessment and opened assessment proceedings afresh, but the AO may tax only income items for which reasons to believe were recorded. The AO improperly reduced deductions under ss.80HH/80I and could not raise issues (club fees, gifts) not covered by the recorded reasons without issuing fresh s.148 notice. The Tribunal was correct that the AO has jurisdiction to reassess other matters, but not where the original reasons for reopening no longer subsist. en-us Fri, 03 Jun 2011 00:00:00 +0530 Fri, 05 Sep 2025 14:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203601 HC allowed the appeal, holding that issuance of notice under s.148 set aside the earlier assessment and opened assessment proceedings afresh, but the AO may tax only income items for which reasons to believe were recorded. The AO improperly reduced deductions under ss.80HH/80I and could not raise issues (club fees, gifts) not covered by the recorded reasons without issuing fresh s.148 notice. The Tribunal was correct that the AO has jurisdiction to reassess other matters, but not where the original reasons for reopening no longer subsist. Case-Laws Income Tax Fri, 03 Jun 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203601