https://www.taxtmi.com/caselaws?id=752174 Gujarat HC quashed reassessment notices under Section 148 issued based on survey of Jammu Kashmir Bank. The assessee had disclosed all foreign exchange transactions and bank details during original assessment. The bank's survey report showed two different remittance calculations - notional and actual realization rates. Since the assessee had already provided complete documentation including bank statements, exchange differences, and Form-15CA during original proceedings, the AO lacked fresh tangible material to form prima facie belief of income escapement. The reassessment constituted mere change of opinion without new evidence. Appeal allowed. en-us Mon, 22 Apr 2024 00:00:00 +0530 Tue, 10 Jun 2025 14:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752174 Gujarat HC quashed reassessment notices under Section 148 issued based on survey of Jammu Kashmir Bank. The assessee had disclosed all foreign exchange transactions and bank details during original assessment. The bank's survey report showed two different remittance calculations - notional and actual realization rates. Since the assessee had already provided complete documentation including bank statements, exchange differences, and Form-15CA during original proceedings, the AO lacked fresh tangible material to form prima facie belief of income escapement. The reassessment constituted mere change of opinion without new evidence. Appeal allowed. Case-Laws Income Tax Mon, 22 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752174