https://www.taxtmi.com/caselaws?id=16338 HC quashed notices issued under section 148 and set aside reassessment proceedings for the relevant year, holding that the AO's recorded reasons amounted to a mere change of opinion rather than a bona fide belief of escapement of income. The court found the reasons lacked reasonable nexus to material establishing escapement, and the AO could not expand jurisdiction by framing reasons or relying on Explanation 1. Claims about section 43B adjustments and valuation of closing stock did not supply requisite material to sustain reassessment; accordingly the reassessment notices were invalidated. en-us Tue, 24 Nov 1998 00:00:00 +0530 Thu, 09 Oct 2025 19:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16338 HC quashed notices issued under section 148 and set aside reassessment proceedings for the relevant year, holding that the AO's recorded reasons amounted to a mere change of opinion rather than a bona fide belief of escapement of income. The court found the reasons lacked reasonable nexus to material establishing escapement, and the AO could not expand jurisdiction by framing reasons or relying on Explanation 1. Claims about section 43B adjustments and valuation of closing stock did not supply requisite material to sustain reassessment; accordingly the reassessment notices were invalidated. Case-Laws Income Tax Tue, 24 Nov 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16338