https://www.taxtmi.com/caselaws?id=7922 A reassessment notice issued under section 148 read with section 147(a) was held invalid because a prior appellate finding that the original reopening was unjustified had become final and binding on the department. That concluded finding negatived the statutory basis for reopening on the same foundational facts, so the department could not disregard it and proceed again under section 147(a). Any genuinely fresh material would have had to be considered, if at all, under section 147(b), not section 147(a), and that route was time-barred on the facts noted. The notice was therefore without jurisdiction and was quashed. en-us Wed, 20 May 1970 00:00:00 +0530 Tue, 24 Mar 2009 17:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7922 A reassessment notice issued under section 148 read with section 147(a) was held invalid because a prior appellate finding that the original reopening was unjustified had become final and binding on the department. That concluded finding negatived the statutory basis for reopening on the same foundational facts, so the department could not disregard it and proceed again under section 147(a). Any genuinely fresh material would have had to be considered, if at all, under section 147(b), not section 147(a), and that route was time-barred on the facts noted. The notice was therefore without jurisdiction and was quashed. Case-Laws Income Tax Wed, 20 May 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7922