https://www.taxtmi.com/caselaws?id=411147 The court upheld the legal validity of the notice issued under Section 148 of the Income Tax Act, 1961, finding sufficient reasons to establish a "reason to believe" that income had escaped assessment. It determined that there was an independent application of mind by the Assessing Authority in initiating the reopening proceedings, not solely based on audit objections. The court clarified that the reopening was not a result of a change of opinion and that compliance with mandatory requirements under Section 147 was met. Consequently, the court dismissed the petition, allowing the reassessment proceedings to continue. en-us Tue, 10 Aug 2021 00:00:00 +0530 Fri, 22 Oct 2021 15:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411147 The court upheld the legal validity of the notice issued under Section 148 of the Income Tax Act, 1961, finding sufficient reasons to establish a "reason to believe" that income had escaped assessment. It determined that there was an independent application of mind by the Assessing Authority in initiating the reopening proceedings, not solely based on audit objections. The court clarified that the reopening was not a result of a change of opinion and that compliance with mandatory requirements under Section 147 was met. Consequently, the court dismissed the petition, allowing the reassessment proceedings to continue. Case-Laws Income Tax Tue, 10 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411147