https://www.taxtmi.com/caselaws?id=8892 Reopening under section 148 requires material supporting a bona fide belief that income escaped assessment because the assessee failed to disclose fully and truly all material facts. Here, the later investigation into alleged bogus hundi loan transactions in subsequent years had no nexus with the relevant assessment year and did not show suppression of similar transactions in that year. The reassessment was therefore based on a mere change of opinion rather than fresh material meeting the statutory precondition. The notice was held without jurisdiction, the reassessment notice was quashed, and the writ petition succeeded. en-us Tue, 20 Mar 1973 00:00:00 +0530 Wed, 17 Jun 2009 09:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8892 Reopening under section 148 requires material supporting a bona fide belief that income escaped assessment because the assessee failed to disclose fully and truly all material facts. Here, the later investigation into alleged bogus hundi loan transactions in subsequent years had no nexus with the relevant assessment year and did not show suppression of similar transactions in that year. The reassessment was therefore based on a mere change of opinion rather than fresh material meeting the statutory precondition. The notice was held without jurisdiction, the reassessment notice was quashed, and the writ petition succeeded. Case-Laws Income Tax Tue, 20 Mar 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8892