Reassessment Requires New Evidence, Not Just Opinion Change; Notice Quashed Due to Lack of Income Escapement Proof.

Reassessment cannot be justified merely by a change in the opinion of the Assessing Officer, especially when all relevant information was already considered in the original assessment. The court emphasized that reopening of assessment requires tangible material suggesting income escapement, which was not present in this case. - Notice issued u/s 148 for reassessment u/s 147 qashed - HC .....

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