https://www.taxtmi.com/caselaws?id=442930 HC allowed the taxpayer's petition and quashed the notice under s.148 and related proceedings. The court held the sanction was not obtained as required by s.151(ii) and was improperly granted, the approving order and notice under s.148A(d) being therefore invalid. The HC found the relied-upon instructions inapplicable and stressed that reassessment cannot be based on mere change of opinion; AO must follow the procedure under s.148A(b) and s.148 and cannot review an assessment where relevant particulars were earlier considered. The reopening of assessment was set aside and appeal allowed. en-us Fri, 25 Aug 2023 00:00:00 +0530 Sat, 27 Sep 2025 13:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442930 HC allowed the taxpayer's petition and quashed the notice under s.148 and related proceedings. The court held the sanction was not obtained as required by s.151(ii) and was improperly granted, the approving order and notice under s.148A(d) being therefore invalid. The HC found the relied-upon instructions inapplicable and stressed that reassessment cannot be based on mere change of opinion; AO must follow the procedure under s.148A(b) and s.148 and cannot review an assessment where relevant particulars were earlier considered. The reopening of assessment was set aside and appeal allowed. Case-Laws Income Tax Fri, 25 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442930