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“reopening of assessment”

ReassessmentSections 147-151Sections 147-1514,262 judgments

The decision most relied on for reopening of assessment is GKN Driveshafts (India) Ltd. v. ITO (259 ITR 19), cited in 1,349 judgments on BharatTax.

Leading authorities on reopening of assessment

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Lovely Exports (P) Ltd.
216 CTR 195 · 2008 · Supreme Court
854
citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Judgments citing reopening of assessment

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2187/KOL/2024[2015-16]Status: DisposedITAT Kolkata28 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

adjudication. A.Y. 2013-14 CO No. 42/KOL/2025 04. Since, the assessee has raised legal issue in cross objection filed, challenging the validity of reopening of assessment u/s 147 of the Income-tax Act, 1961 (the Act) on the ground that the conditions envisaged in proviso to Section ... premises of the assessee on 04.011.2019, during which some documents were found. Based on the findings of the survey team, the ld. AO reopened the assessment u/s 147 of the Income-tax Act, 1961 (the Act) by issuing notice u/s 148 of the Act on 01.04.2021, which were duly served

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2179/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

adjudication. A.Y. 2013-14 CO No. 42/KOL/2025 04. Since, the assessee has raised legal issue in cross objection filed, challenging the validity of reopening of assessment u/s 147 of the Income-tax Act, 1961 (the Act) on the ground that the conditions envisaged in proviso to Section ... premises of the assessee on 04.011.2019, during which some documents were found. Based on the findings of the survey team, the ld. AO reopened the assessment u/s 147 of the Income-tax Act, 1961 (the Act) by issuing notice u/s 148 of the Act on 01.04.2021, which were duly served

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Ltd., Kolkata

In the result, the appeals of the Revenue are dismissed and the

ITA 2178/KOL/2024[2013-14]Status: DisposedITAT Kolkata28 Oct 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

adjudication. A.Y. 2013-14 CO No. 42/KOL/2025 04. Since, the assessee has raised legal issue in cross objection filed, challenging the validity of reopening of assessment u/s 147 of the Income-tax Act, 1961 (the Act) on the ground that the conditions envisaged in proviso to Section ... premises of the assessee on 04.011.2019, during which some documents were found. Based on the findings of the survey team, the Id. AO reopened the assessment u/s 147 of the Income-tax Act, 1961 (the Act) by issuing notice u/s 148 of the Act on 01.04.2021, which were duly served

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3239/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

referred to as CIT (A)) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that order be quashed. Ground no.2 Without prejudice to the above, the CIT(A) erred in holding that the AO was right in making

Ei Beneficiary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025

ITA 3235/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Oct 2025AY 2017-18
Section 132Section 132(4)Section 69A

referred to as CIT (A)) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that the Order be quashed. Ground no.2 Without prejudice to the above, the CIT (A) erred in holding that AO was right in making

Ei Beneficary Trust, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3230/Mum/2025 Govind

ITA 3234/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

referred to as CIT (A)) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that the Order be quashed. Ground no.2 Without prejudice to the above, the CIT (A) erred in holding that AO was right in making

Govind Corporation, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3230/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

referred to as CIT (A)) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that the Order be quashed. Ground no.2 Without prejudice to the above, the CIT (A) erred in holding that AO was right in making

Tarun Nandkumar Seksaria, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3216/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16
Section 132Section 132(4)Section 69A

referred to as CIT (A)) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under Section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that order be quashed. Ground no.2 Without prejudice to the above, the CIT(A) erred in holding that the AO was right in making

Tarun Nandkumar Seksaria, Mumbai vs. DCIT Central Circle 8(1), Mumbai

ITA 3215/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17
Section 132Section 132(4)Section 69A

referred to as CIT (A)) erred in holding that the DCIT, Central Circle 8(1) (herein referred to as AO) was right in reopening the assessment under Section 148 of the Act. The Appellants submit that the conditions precedent to reopening of the assessment are not compiled with ... Order passed by the AO is without jurisdiction and therefore the reopening of assessment is bad in law and void ab-initio and the Appellants pray that order be quashed. Ground no.2 Without prejudice to the above, the CIT(A) erred in holding that the AO was right in making

Anshuman Auto Impex Private Limited, New Delhi vs. Income Tax Officer, Ward 2(1), New Delhi

In the result, the appeal is dismissed

ITA 4152/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Oct 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2016-17 Vs. Income Tax Officer, Anshuman Auto Impex Pvt. Ltd., Ward-2(1), 2126/59, Laxmi Bhawan, New Delhi Naiwala, Karol Bagh, New Delhi Pan: Aaaca0872H (Appellant) (Respondent) Assessee By None Department By Sh. Manish Gupta, Sr. Dr

Section 147Section 148

that there had been escapement of income of assessee from assessment because of his failure to disclose fully and truly all material facts, reopening of assessment was justified" (ii) Hon'ble Gujarat High Court decision in case of Peass Industrial Engineers 73 Taxmann 185 (Gujarat) wherein it was held that ... justified in reopening of assessment proceedings on the basis of information received from Investigation Wing that the assessee was one of the beneficiaries of bogus accommodation entry providers (iii) AO justified in reopening of assessment proceedings on the basis of information given by investigation wing-110 Taxmann 174 (Gujarat

Dy. Commissioner of Income Tax, Central Circle-17, Delhi vs. Ashwani Kumar Gupta, Lucknow

In the result, both the Revenue appeals stand dismissed

ITA 3020/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Oct 2025AY 2013-14

Bench: Sh. M Balaganesh & Sh. Sudhir Kumar & Dcit, Central Circle-17, Vs. Ashwani Kumar Gupta, Delhi Gokhley Marg Room No. 244, Ara Lucknow Centre, Jhandewalan Uttar Pradesh-226001 Extension, New Delhi

Section 132Section 153ASection 153CSection 153C(1)

principles enunciated by us and which explain how the period of six and ten AYs' is liable to be computed, the reopening of assessments pertaining to AYs' 2010-11, 2011-12, 2012-13 and 2013-14 would clearly fall beyond the ambit of ten AYs' as provided under Section 153C

DCIT, Central Circle-17, Delhi vs. Ashwani Kumar Gupta, Lucknow

In the result, both the Revenue appeals stand dismissed

ITA 3019/DEL/2025[2012-13]Status: DisposedITAT Delhi28 Oct 2025AY 2012-13

Bench: Sh. M Balaganesh & Sh. Sudhir Kumar & Dcit, Central Circle-17, Vs. Ashwani Kumar Gupta, Delhi Gokhley Marg Room No. 244, Ara Lucknow Centre, Jhandewalan Uttar Pradesh-226001 Extension, New Delhi

Section 132Section 153ASection 153CSection 153C(1)

principles enunciated by us and which explain how the period of six and ten AYs' is liable to be computed, the reopening of assessments pertaining to AYs' 2010-11, 2011-12, 2012-13 and 2013-14 would clearly fall beyond the ambit of ten AYs' as provided under Section 153C

ACIT, Circle, Gandhidham vs. Kutch District Co-Operative Milk Producers Union Limited, Anjar

In the result, appeal find by the revenue is dismissed

ITA 212/RJT/2025[2017-18]Status: DisposedITAT Rajkot27 Oct 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.212/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2017-18 The Acit, Circle, Kutch District Co-Operative बनाम Gandhidham Milk Producers Union Ltd. Vs. C.O. Apmc Premises, Versamedi Naka, Near Railway Crossing Anjar, Gujarat-37010 Pan : Aaaak9845N (अपीलाथ"/Appellant) (""यथ"/Respondent) : "नधा"रती क" ओर से/Assessee By : Shri Akshay Modi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr

For Appellant: Shri Akshay Modi, ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 143(3)Section 144BSection 250Section 263Section 80PSection 80P(2)(d)

supplant his own view with the view taken by the assessing officer. Further, the decision of KatlaryKariana Supra was on the aspect of reopening of assessment under Section 147 of the Act and not directly on the issue of claim of reduction under Section 80P of the Act. Therefore, once

Sivadurgavara Prasad Chennupati, Vijayawada vs. Assistant CIT, Circle 2(1), Vijayawada

In the result, the appeal by the assessee is allowed

ITA 368/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Oct 2025AY 2016-17

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailita No.368/Viz/2025 (Assessment Year 2016-17) (Assessment Year 2016-17) Sivadurgavara Prasad Chennupati, H. No. 27-32-27, Raghu Paints, Mudda Subbaiah Street, Governorpet, Vijayawada ............... Appellant Pan: Aeepc5404L V/S Assistant Commissioner Of Income Tax, Circle – 2(1), ……………… Respondent C R Building, 1St Floor Annex, M.G. Road, Vijayawada Assessee By : Shri C.R. Hemanth Kumar, Ca Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Shri C.R. Hemanth Kumar, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 149(1)Section 250Section 28

also raised the grounds on merits, challenging the addition made by the Assessing Officer (“AO”). Since the grounds challenging the reopening of assessment under section 147 of the Act have raised a jurisdictional issue, they are considered at the outset. 6. During the hearing, the learned Authorised Representative (“learned

Siva Durga Vara Prasad Chennupati, Vijayawada vs. Assistant Commissioner of Income Tax, Circle 2(1), Vijayawada

In the result, the appeal by the assessee is allowed

ITA 367/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Oct 2025AY 2016-17

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailita No.368/Viz/2025 (Assessment Year 2016-17) (Assessment Year 2016-17) Sivadurgavara Prasad Chennupati, H. No. 27-32-27, Raghu Paints, Mudda Subbaiah Street, Governorpet, Vijayawada ............... Appellant Pan: Aeepc5404L V/S Assistant Commissioner Of Income Tax, Circle – 2(1), ……………… Respondent C R Building, 1St Floor Annex, M.G. Road, Vijayawada Assessee By : Shri C.R. Hemanth Kumar, Ca Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Shri C.R. Hemanth Kumar, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 149(1)Section 250Section 28

also raised the grounds on merits, challenging the addition made by the Assessing Officer (“AO”). Since the grounds challenging the reopening of assessment under section 147 of the Act have raised a jurisdictional issue, they are considered at the outset. 6. During the hearing, the learned Authorised Representative (“learned

Katrathal Gram Sewa Sahkari Samiti Limited, Katrathal vs. ITO Ward 1 Sikar, Sikar

The appeal is dismissed

ITA 1001/JPR/2025[2019-20]Status: DisposedITAT Jaipur27 Oct 2025AY 2019-20
For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 139(1)Section 143(2)Section 144BSection 147Section 147rSection 148Section 148ASection 151Section 234ASection 250

that the AO has to restrict the assessment or reassessment proceedings only to the issues in respect of which reasons were recorded for reopening the assessment—However, Expln. 3 does not and cannot override the necessity of fulfilling the conditions set out in the substantive part of s.147 ... Assessee's ground allowed. (j) In the case of CIT(EXEMPTION) vs. B.P. Poddar Foundation ForEducationSep 13, 2022 (2022) 115 CCH 0026 KolHCReassessment— Reopening of assessment—Assessee filed return of income declaring a total income of Rs. NIL—Return was processed under Section 143 (1—A survey was conducted from

Pooja Kansal, Chandigarh vs. Income Tax Officer, Ward-1, G.Garh, Gobindgarh

In the result, the Assessee’s appeal is allowed

ITA 225/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh27 Oct 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 224 & 225/Chd/2025 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18 Pooja Kansal, The Ito, बनाम Kansla Singla & Ward -1, Associates, Gobindgarh Vs. Sco 80-81, Sector 17-C, Chandigarh "थायी लेखा सं./Pan No. Abypk5904G अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. T.N. Singla, Ca राज"व क" ओर से/ Revenue By : Smt. Kusum Kashyap, Cit Dr (Virtual Mode) सुनवाई क" तार"ख/Date Of Hearing : 12.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.10.2025 आदेश/Order Per Krinwant Sahay, Am: Both The Appeals Pertaining To A.Ys. 2016-17 & 2017- 18 Have Been Filed By The Assessee Against The Separate

For Appellant: Sh. T.N. Singla, CAFor Respondent: Smt. Kusum Kashyap, CIT DR
Section 147Section 148Section 234ASection 250Section 271(1)(c)Section 65A

issue of reopening of the assessment u/s 147 / 148. Since we have already decided the issue on merit, therefore, this issue of reopening of assessment is just academic in nature, we are not inclined to decide this issue. 13 224 & 225-Chd-2025 – Pooja Kansal, Chandigarh 10. In the result

Pooja Kansal, Chandigarh vs. Income Tax Officer, Ward-1, G.Garh, Gobindgarh

In the result, the Assessee’s appeal is allowed

ITA 224/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh27 Oct 2025AY 2016-17

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 224 & 225/Chd/2025 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18 Pooja Kansal, The Ito, बनाम Kansla Singla & Ward -1, Associates, Gobindgarh Vs. Sco 80-81, Sector 17-C, Chandigarh "थायी लेखा सं./Pan No. Abypk5904G अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. T.N. Singla, Ca राज"व क" ओर से/ Revenue By : Smt. Kusum Kashyap, Cit Dr (Virtual Mode) सुनवाई क" तार"ख/Date Of Hearing : 12.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.10.2025 आदेश/Order Per Krinwant Sahay, Am: Both The Appeals Pertaining To A.Ys. 2016-17 & 2017- 18 Have Been Filed By The Assessee Against The Separate

For Appellant: Sh. T.N. Singla, CAFor Respondent: Smt. Kusum Kashyap, CIT DR
Section 147Section 148Section 234ASection 250Section 271(1)(c)Section 65A

issue of reopening of the assessment u/s 147 / 148. Since we have already decided the issue on merit, therefore, this issue of reopening of assessment is just academic in nature, we are not inclined to decide this issue. 13 224 & 225-Chd-2025 – Pooja Kansal, Chandigarh 10. In the result

Deputy Commissioner of Income Tax, Jalgaon vs. Taradevi Ratanlal Bafna, Jalgaon

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 497/PUN/2025[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

accepting the income returned. 4. Subsequently on the basis of information received from the Investigation Wing, Nashik, the Assessing Officer reopened the assessment as per provisions of section 147 of the Act by recording the following reasons: INCOME TAX DEPARTMENT GOVERNMENT OF INDIA MINISTRY OF FINANCE INCOME TAX DEPARTMENT OFFICE ... issued of notice u/s.148 for A.Y.2015-16-Reg. Ref: Your Letter dated 30.07.2020 received in this office on 10.08.2020 03. Accordingly the reasons for reopening the assessment u/s 147 of the Act for the A.Y.2015-16 are reproduced as under:- 1. The assessee is an individual having share income from business profits being

Shresth Dealers Pvt. Ltd., Kolkata vs. DCIT, CC 4(1), Kolkata

Appeal of the assessee is allowed

ITA 427/KOL/2025[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 250

application of mind by the AO at the time of recording reasons. The reasons were recorded on wrong facts. In our opinion, reopening of assessment is bad in law and so is the assessment framed. Accordingly, we quash the notice u/s 148 as well as assessment framed