https://www.taxtmi.com/caselaws?id=18780 The court quashed the reassessment notice under section 148 read with section 147 of the Income-tax Act, 1961 for the assessment year 1990-91. The court emphasized that the Assessing Officer must have valid reasons to believe that income has escaped assessment and must provide a basis for such belief. Mere assertion without disclosing reasoning does not confer jurisdiction for reassessment. The court held that section 147 does not allow a change of opinion without new material. As the necessary conditions for issuing the notice were not satisfied, the court ruled in favor of the petitioner and allowed the petition, quashing the notice. en-us Thu, 07 Sep 1995 00:00:00 +0530 Mon, 02 Nov 2009 10:23:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18780 The court quashed the reassessment notice under section 148 read with section 147 of the Income-tax Act, 1961 for the assessment year 1990-91. The court emphasized that the Assessing Officer must have valid reasons to believe that income has escaped assessment and must provide a basis for such belief. Mere assertion without disclosing reasoning does not confer jurisdiction for reassessment. The court held that section 147 does not allow a change of opinion without new material. As the necessary conditions for issuing the notice were not satisfied, the court ruled in favor of the petitioner and allowed the petition, quashing the notice. Case-Laws Income Tax Thu, 07 Sep 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18780