https://www.taxtmi.com/forum/issue?id=108692 Reopening under section 147/148 demands a recorded reason to believe based on new material that directly links to escapement of income; mere suspicion or a change of opinion is insufficient. Valid reopenings rest on disclosure failures or freshly discovered material, subject to statutory authorisation and time-limit controls. On receiving a section 148 notice the assessee should file the return, obtain the reasons recorded, raise specific objections seeking a speaking order, and may pursue writ remedies if the reopening lacks statutory basis. en-us Wed, 03 Jun 2015 19:17:56 +0530 Thu, 23 Jan 2025 15:56:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=108692 Reopening under section 147/148 demands a recorded reason to believe based on new material that directly links to escapement of income; mere suspicion or a change of opinion is insufficient. Valid reopenings rest on disclosure failures or freshly discovered material, subject to statutory authorisation and time-limit controls. On receiving a section 148 notice the assessee should file the return, obtain the reasons recorded, raise specific objections seeking a speaking order, and may pursue writ remedies if the reopening lacks statutory basis. Discussion-Forum Income Tax Wed, 03 Jun 2015 19:17:56 +0530 https://www.taxtmi.com/forum/issue?id=108692