2008 (7) TMI 237 - BOMBAY HIGH COURT

Reassessment - notice issued u/s 148 - “reason to believe” - change of opinion - no new material has come on record, no new information has been received, it is merely a fresh application of mind by the same Assessing Officer to the same set of facts - reopening of assessment u/s 147 merely because there is a change of opinion cannot be allowed. In our opinion, therefore, in the present case, it was not permissible for the respondent to issue notice u/s 148.