https://www.taxtmi.com/caselaws?id=436173 The court found that the notice issued under Section 148 of the Income Tax Act lacked tangible material to support the 'reason to believe' requirement for reopening assessments under Section 147. The failure to provide reasons for reopening assessments rendered the actions arbitrary and without jurisdiction. As a result, the court quashed the notice, assessment order, and penalty proceedings initiated under Section 271D. The court held that the Assessing Officer did not meet the jurisdictional conditions and procedural requirements, leading to the allowance of the writ petition without costs. en-us Wed, 08 Mar 2023 00:00:00 +0530 Tue, 20 Jun 2023 10:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436173 The court found that the notice issued under Section 148 of the Income Tax Act lacked tangible material to support the 'reason to believe' requirement for reopening assessments under Section 147. The failure to provide reasons for reopening assessments rendered the actions arbitrary and without jurisdiction. As a result, the court quashed the notice, assessment order, and penalty proceedings initiated under Section 271D. The court held that the Assessing Officer did not meet the jurisdictional conditions and procedural requirements, leading to the allowance of the writ petition without costs. Case-Laws Income Tax Wed, 08 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436173