Assessing Officer issued a notice under section 148A(b), alleging that the assessee had claimed fictitious losses in equity/derivatives trading. Assessee explained that it had invested in an equity hybrid mutual fund, earned dividends therefrom, and furnished supporting bank and mutual fund statements. The Assessing Officer rejected the explanation, alleged that dividends were generated through sham and colourable transactions, concluded that dividend income should be taxed, and thereafter issued notice under section 148. High Court held that since the reasoning assigned in the order under section 148A(d) was de hors the allegations which had come to be originally laid against the assessee while issuing notice under section 148A(b), formation of opinion could not be based on a set of reasons which were of changing hues, and, therefore, the order under section 148A(d) and notice under section 148 were quashed. SLP of revenue was dismissed.  (AY. 2018-19)