TMI Blog1993 (4) TMI 316X X X X Extracts X X X X X X X X Extracts X X X X ..... ner for quashing the notice issued under s. 148 of the IT Act, 1961, which is Annexure-3 to this application. The petitioner has been called upon to file return of income-tax for the asst. yr. 1990-91. The sole ground on which the notice has been issued under s. 148 of the IT Act is challenged is that the Assessing Officer before issuing the notice has not recorded his reasons and, therefore, has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Such reasons must, therefore, have particular reference to the case of the assessee, though it should not be in the form of a detailed judgment containing all the reasons and the justification for the same, but must objectively satisfy any person examining the order that the Assessing Officer has applied his mind to the facts of the case and has issued the notice. 4. In the instant case we fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t to appreciate as to what was in the mind of the ITO or what was the material on record which led him to believe that the assessee had not fully and truly disclosed all material facts necessary for assessment and consequently receipts chargeable to tax had escaped assessment for the year. It is well settled that mere change of mind on the basis of some material without anything else is not suffic ..... X X X X Extracts X X X X X X X X Extracts X X X X
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