https://www.taxtmi.com/caselaws?id=264085 The court held that the reassessment proceedings initiated under Sections 147 and 148 of the Income Tax Act for the assessment year 2007-08 were erroneous as they constituted a change of opinion without proper application of mind. The court emphasized that an audit report cannot solely constitute "reasons to believe" for income escaping assessment, and the Income Tax Officer must independently assess the situation. Consequently, the court quashed the notice under Section 148 and the order rejecting the petitioner's objections, ruling in favor of the petitioner. en-us Tue, 08 Sep 2015 00:00:00 +0530 Fri, 20 Nov 2015 11:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264085 The court held that the reassessment proceedings initiated under Sections 147 and 148 of the Income Tax Act for the assessment year 2007-08 were erroneous as they constituted a change of opinion without proper application of mind. The court emphasized that an audit report cannot solely constitute "reasons to believe" for income escaping assessment, and the Income Tax Officer must independently assess the situation. Consequently, the court quashed the notice under Section 148 and the order rejecting the petitioner's objections, ruling in favor of the petitioner. Case-Laws Income Tax Tue, 08 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264085