Question And Answer
Subject: Section 147 r.w.s 148 to 153
Querist: Prince Jindal
Answered by:
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Date: April 2, 2022
Query asked by Prince Jindal

A notice under section 148A has been issued on the assessee for re-assessment of AY 2018-19. Since the assessee was already assessed for AY 2018-19 in an earlier assessment. Can the assessee do the following on receipt of notice under section 148A:

(1) Ask the AO for providing the ‘reasons to believe,’ considering that under the new regime notice under section 148 is issued on the basis of the ‘information with the Assessing Officer which suggests that the income chargeable to tax has escaped assessment’?

(2) Can the assessee object to the reasons to believe furnished by the AO on the grounds of ‘change in opinion,’ considering the assessee for AY 2018-19 has already been assessed?

(3) whether the contention of ‘change of opinion’ (based on earlier judicial precedents) is still valid under the new regime?

Thanks in advance!

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The Assessee cannot ask for a copy of the recorded reasons, as the same is provided in the form of “information” along with Notice under section 148A of the Act.

Yes, the assessee has to object to the “information ” which is in the possession of the Ld. AO.

In our opinion, the concept of “Change of Opinion” is still valid, as no authority has the power to review its own order unless expressly provided by the statute.

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