Challenging Tax Reassessment: Section 148 Notice Invalidated Due to Lack of Jurisdictional Grounds and Insufficient Evidence

HC determined the invalidity of a Section 148 notice challenging the Assessing Officer's (AO) assumption regarding material advances and closing stock discrepancies. The court found that the AO erroneously interpreted material advances as an indication of understated closing stock, despite the advance being already accounted for in the revenue bill. The AO lacked jurisdiction to reopen the assessment based on information already examined during the original assessment. Consequently, the HC quashed the reassessment notice, ruling in favor of the assessee and determining that the purported stock variation could not substantiate claims of escaped income. .....

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