Reassessment based on reviewed loan evidence fails without fresh material, while post-April electronic notices require section 148A compliance. https://www.taxtmi.com/highlights?id=104611 Reassessment of a loan credit previously examined in scrutiny cannot rest on the same confirmation, bank statements and balance sheet without fresh information or tangible material; adopting a different view is an impermissible change of opinion. Separately, an electronic notice served on or after 1 April 2021 must follow section 148A: a show-cause notice, supply of material, consideration of the taxpayer's reply, and an order before issuing a notice under section 148. Failure to follow this sequence invalidates reassessment. On these independent grounds, the reassessment notice and consequential order were quashed, without deciding the loan-credit addition on merits. en-us Wed, 07 Oct 2026 08:26:38 +0530 Wed, 07 Oct 2026 08:26:40 +0530 TaxTMI RSS Generator Reassessment based on reviewed loan evidence fails without fresh material, while post-April electronic notices require section 148A compliance. https://www.taxtmi.com/highlights?id=104611 Reassessment of a loan credit previously examined in scrutiny cannot rest on the same confirmation, bank statements and balance sheet without fresh information or tangible material; adopting a different view is an impermissible change of opinion. Separately, an electronic notice served on or after 1 April 2021 must follow section 148A: a show-cause notice, supply of material, consideration of the taxpayer's reply, and an order before issuing a notice under section 148. Failure to follow this sequence invalidates reassessment. On these independent grounds, the reassessment notice and consequential order were quashed, without deciding the loan-credit addition on merits. Highlights Income Tax Wed, 07 Oct 2026 08:26:38 +0530 https://www.taxtmi.com/highlights?id=104611