The show cause notice was issued to reopen the assessment on the ground that the assessee ‘s return of income did not offer to tax receipts of professional service charges from S.R. Botliboi and Associates LLP.   The petitioner challenged the order passed under section 148A(d) and notice issued under section 148 of the Act. Dismissing the petition the Court held that there was no infirmity in the order passed by the Assessing Officer under section 148A(d) for issue of notice under section 148 of the Act. Court also held that  when the original assessment proceeding has been completed under section 143(1) of the Income-tax Act, 1961, there is no need for fresh tangible material for reopening the assessment under section 147 since there is a distinction between “intimation” and “assessment” under section 143(1) and 143(3). Consequently, the order passed under section 143(1) is not an assessment for the purposes of section 147 and therefore, it is not necessary for the Assessing Officer to come across some fresh tangible material to form a belief that income has escaped assessment. (AY.2018-19)