https://www.taxtmi.com/caselaws?id=768379 A reassessment notice under section 148A(b) must disclose material showing escapement of income, and a later section 148A(d) order cannot be sustained on new grounds not stated in the original notice. Mere reference to disclosed receipts or an exemption claim is insufficient to establish escapement, and the Assessing Officer cannot supplement the recorded basis by introducing a different theory, such as permanent establishment or treaty taxability, at the objections stage. The section 148A(b) notice, the section 148A(d) order, and the consequent section 148 notice were therefore invalid and set aside. en-us Mon, 24 Mar 2025 00:00:00 +0530 Sat, 05 Apr 2025 08:23:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768379 A reassessment notice under section 148A(b) must disclose material showing escapement of income, and a later section 148A(d) order cannot be sustained on new grounds not stated in the original notice. Mere reference to disclosed receipts or an exemption claim is insufficient to establish escapement, and the Assessing Officer cannot supplement the recorded basis by introducing a different theory, such as permanent establishment or treaty taxability, at the objections stage. The section 148A(b) notice, the section 148A(d) order, and the consequent section 148 notice were therefore invalid and set aside. Case-Laws Income Tax Mon, 24 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768379