https://www.taxtmi.com/caselaws?id=392505 The court held that the second notice issued under Section 148 of the Income-tax Act was not justified as it was based on a mere change of opinion without new tangible material. The Assessing Officer lacked a valid "reason to believe" that income had escaped assessment. Therefore, the assumption of jurisdiction under Section 147 was deemed unsustainable. The writ petition was allowed, and the impugned notice dated March 3, 2015, was quashed. No order as to costs was given. en-us Tue, 05 Nov 2019 00:00:00 +0530 Fri, 21 Feb 2020 15:06:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=392505 The court held that the second notice issued under Section 148 of the Income-tax Act was not justified as it was based on a mere change of opinion without new tangible material. The Assessing Officer lacked a valid "reason to believe" that income had escaped assessment. Therefore, the assumption of jurisdiction under Section 147 was deemed unsustainable. The writ petition was allowed, and the impugned notice dated March 3, 2015, was quashed. No order as to costs was given. Case-Laws Income Tax Tue, 05 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=392505