2019 (12) TMI 265

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....i, for the Petitioner in both matters. Mr.Sham Walve, for Respondents in both the matters. ORDER P.C. : Heard. Rule. 2. These two Petitions under Article 226 of the Constitution of India challenge two separate notices dated 27 March 2019 issued by the Assessing Officer under section 148 of the Income Tax Act, 1961 (the 'Act') respectively. The impugned notices seek to reopen the ass....

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....ng to reason to believe that income chargeable to tax had escaped assessment were the subject matter of consideration while passing the order under section 143(3) of the Act. Therefore, prima facie the impugned notices appear to be based on change of opinion. Besides, there being no failure on the part of the Petitioner to disclose truly and fully all material facts necessary for assessment during....