https://www.taxtmi.com/caselaws?id=17183 Reassessment notices under s.148 were challenged as being issued without "reason to believe" under s.147 and amounting to a mere change of opinion. The HC held that the assessee had fully and truly disclosed all material facts during the original assessment, and the assessing authority had already considered the income for the relevant year. The recorded reasons did not disclose any objective material capable of forming the requisite belief and reflected, at most, suspicion or reappraisal of the same facts; such action is without jurisdiction and cannot be supported by reasons beyond those recorded. Consequently, the impugned s.148 notices were quashed and the writ petitions were allowed. en-us Fri, 05 Dec 1997 00:00:00 +0530 Tue, 30 Dec 2025 10:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17183 Reassessment notices under s.148 were challenged as being issued without "reason to believe" under s.147 and amounting to a mere change of opinion. The HC held that the assessee had fully and truly disclosed all material facts during the original assessment, and the assessing authority had already considered the income for the relevant year. The recorded reasons did not disclose any objective material capable of forming the requisite belief and reflected, at most, suspicion or reappraisal of the same facts; such action is without jurisdiction and cannot be supported by reasons beyond those recorded. Consequently, the impugned s.148 notices were quashed and the writ petitions were allowed. Case-Laws Income Tax Fri, 05 Dec 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17183