https://www.taxtmi.com/caselaws?id=27305 A reassessment notice under section 148 was invalid where the recorded reasons showed only a reappraisal of material already considered in the completed section 143(3) assessment, amounting to a mere change of opinion. The court held that jurisdiction for reopening must rest on reasons actually recorded by the Assessing Officer; an internal handwritten note not forming part of the recorded reasons cannot be treated as statutory compliance under section 148(2) or supply jurisdiction under sections 147(a) or 147(b). The notice was therefore quashed, as the reopening could not be sustained on extraneous material. en-us Thu, 14 Mar 1985 00:00:00 +0530 Fri, 12 Feb 2010 10:43:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27305 A reassessment notice under section 148 was invalid where the recorded reasons showed only a reappraisal of material already considered in the completed section 143(3) assessment, amounting to a mere change of opinion. The court held that jurisdiction for reopening must rest on reasons actually recorded by the Assessing Officer; an internal handwritten note not forming part of the recorded reasons cannot be treated as statutory compliance under section 148(2) or supply jurisdiction under sections 147(a) or 147(b). The notice was therefore quashed, as the reopening could not be sustained on extraneous material. Case-Laws Income Tax Thu, 14 Mar 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27305