Allowing the appeal of the revenue the Court held that, High Court should decide (i) validity of S. 148 notice where assessment is made u/s. 143(1) & not u/s 143(3), (ii) whether notice can be said to be based on change of opinion if there is no foundation to form any such opinion, (iii) Whether requirements of S. 148 are satisfied, namely, that it contains the facts constituting the “reasons to believe” and furnishes the necessary details for assessing the escaped income and (iv) whether finding recorded by ITAT on merits is legally sustainable. (CA No.3450  of  2019, dt. 08.04.2019)( AY. 1999-2000)