https://www.taxtmi.com/caselaws?id=471547 Section 148A requires the Assessing Officer to consider the assessee's response and all available material before issuing a reassessment notice under Section 148. Reassessment for alleged bogus purchases was impermissible where purchase details had been examined during original scrutiny and were resubmitted in response to the Section 148A(b) notice, but were not evaluated in the Section 148A(d) order. Reliance on an undisclosed third-party statement, without an opportunity for rebuttal, did not independently establish income escaping assessment. Reopening on the same previously examined material constituted a change of opinion. Consequently, the Section 148A(d) order, Section 148 notice and reassessment were quashed. en-us Tue, 08 Apr 2025 00:00:00 +0530 Tue, 08 Sep 2026 19:18:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471547 Section 148A requires the Assessing Officer to consider the assessee's response and all available material before issuing a reassessment notice under Section 148. Reassessment for alleged bogus purchases was impermissible where purchase details had been examined during original scrutiny and were resubmitted in response to the Section 148A(b) notice, but were not evaluated in the Section 148A(d) order. Reliance on an undisclosed third-party statement, without an opportunity for rebuttal, did not independently establish income escaping assessment. Reopening on the same previously examined material constituted a change of opinion. Consequently, the Section 148A(d) order, Section 148 notice and reassessment were quashed. Case-Laws Income Tax Tue, 08 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471547