https://www.taxtmi.com/caselaws?id=15754 HC held the notice issued under s.148 invalid: the AO never genuinely held the belief that income escaped assessment on account of erroneous computation under s.80HHC, and the reasons recorded were a pretence. The court found the reassessment proceeded from mere change of opinion and routine Board instructions to initiate remedial action on audit objections, not from independent satisfaction by the AO with jurisdiction to issue the notice. Such procedural façade cannot validate reassessment; the petition was allowed. en-us Tue, 29 Dec 1998 00:00:00 +0530 Thu, 09 Oct 2025 18:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15754 HC held the notice issued under s.148 invalid: the AO never genuinely held the belief that income escaped assessment on account of erroneous computation under s.80HHC, and the reasons recorded were a pretence. The court found the reassessment proceeded from mere change of opinion and routine Board instructions to initiate remedial action on audit objections, not from independent satisfaction by the AO with jurisdiction to issue the notice. Such procedural façade cannot validate reassessment; the petition was allowed. Case-Laws Income Tax Tue, 29 Dec 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15754