Allowing the petition the Court held that, the original assessment was passed under S. 158BC read with S 143(3) of the Act. Bank details were verified . An attempt of the next incumbent officer who issued notice under S 148 ,is a mere change of opinion. Accordingly the notice is held to be not valid .(AY.1997-98, 1998-99, 1999-2000)
P. A. Ahamed. v. CIT (2018) 409 ITR 530 /( 2019) 177 DTR 341/ 308 CTR 574 (Ker)(HC)
S.147:Reassessment –With in four years-Change of opinion- Block assessment -Notice to reassess amount discovered during post search enquiries is held to be not valid . [ S.132,148, 158BC ]