The assessee, engaged in the real estate business, filed his return of income for AY 2013-14 in September 2013, declaring total income of ₹54,91,960. The assessment under Section 143(3) was completed on 31.12.2015, accepting the returned income. Subsequently, on 29.11.2017, a notice under Section 263 was issued by the CIT, questioning non-disclosure of ₹2,74,94,950 from the sale of six flats, disallowance of interest payments, and unreported house property income. The CIT set aside the original assessment order on 16.03.2018, directing a fresh examination. The AO, in compliance, passed a reassessment order on 14.12.2018 under Section 143(3) r.w.s. 263, assessing income at ₹57,06,250 by making an addition on account of notional rent under Income from House Property. Subsequently, on 25.03.2021, the AO issued a notice under Section 148 to reassess AY 2013-14, prompting the assessee to file a return in January 2022. The reasons for reopening were provided in March 2021, and the assessee objected in March 2022, contending that the same issues were already subject to Section 263 proceedings, making reopening invalid under the third proviso to Section 147. Further he contended that the reopening was based on a change of opinion and that the sanction under Section 151 was not valid. The AO rejected the objections on 11.03.2022, justifying reassessment based on oversight or inadvertence in the original proceedings. Aggrieved, the assessee filed a writ petition, the Bombay High Court quashed the reassessment notices for AY 2013-14 and AY 2014-15, holding that, the original assessment order (31.12.2015) no longer existed, as it was set aside under Section 263, making the reopening procedurally invalid. Further it held that the reassessment was based on the same grounds already examined in 263 proceedings, violating the third proviso to Section 147 and no failure to fully and truly disclose material facts was demonstrated. It also held that reopening constituted an impermissible review of the earlier order, not a valid exercise of reassessment jurisdiction. Accordingly, the court ruled in favor of the assessee and set aside the reassessment proceedings. [WP No. 2771/2022 & 2021/2022, dt.  20.02.2025) (AY. 2013-14 ,  2014-15]