https://www.taxtmi.com/caselaws?id=203695 The court held that the notices issued under Section 148 of the Income Tax Act were invalid as they did not meet the mandatory requirement of stating reasons for believing income had escaped assessment. Reassessment proceedings for the assessment years 1991-92 and 1992-93 were barred by limitation and quashed. However, for the assessment year 1993-94, the reassessment was deemed valid as the reasons recorded satisfied the legal requirements. The court emphasized that reassessment cannot be based on a mere change of opinion but must have tangible materials to justify it. en-us Wed, 04 Aug 2010 00:00:00 +0530 Sat, 24 Mar 2012 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203695 The court held that the notices issued under Section 148 of the Income Tax Act were invalid as they did not meet the mandatory requirement of stating reasons for believing income had escaped assessment. Reassessment proceedings for the assessment years 1991-92 and 1992-93 were barred by limitation and quashed. However, for the assessment year 1993-94, the reassessment was deemed valid as the reasons recorded satisfied the legal requirements. The court emphasized that reassessment cannot be based on a mere change of opinion but must have tangible materials to justify it. Case-Laws Income Tax Wed, 04 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203695