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“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Pr. CIT v. Silver Line
383 ITR 455 · 2016 · High Court
201
citing judgments

For reassessment under Section 147, the Assessing Officer must record reasons and communicate them to the assessee. An assessee's participation in proceedings pursuant to a Section 148 notice does not obviate the mandatory requirement of recording and communicating reasons or issuing a Section 143(2) notice.

Judgments citing reasons recorded

Shyam Sunder, Gururgam vs. ITO ( Circle 4(1), Gurgram

In the result, the appeal of the assessee is dismissed

ITA 4779/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Aug 2026AY 2011-12

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 147Section 148Section 2Section 2(14)Section 54BSection 54F

income of Rs.22,37,610/- along with agricultural income of Rs.75,000/-. Thereafter, notice under section 143(2) was issued on 25/09/2018 and the reasons recorded for reopening were supplied to the assessee on 27/09/2018. 3.1 During the course of assessment proceedings, it was noticed that the assessee had sold

Sh Sanjay Bansal, Morena vs. A.C.I.T (Central), Gwalior

In the result, assessee's appeal is dismissed

ITA 31/AGR/2022[2012 - 13]Status: DisposedITAT Agra05 Jun 2026

Bench: learned CIT(Appeals) who has very exhaustively passed the impugned order in 60 pages and considered all the submissions of the assessee in the tabulated form and otherwise, which need not to be repeated again for the sake of brevity. However, learned CIT(Appeals) partly allowed assessee's appeal confirming the addition only to the extent of Rs.71,44,045/- as against addition of Rs.91,06,669/-. 4. Assessee is in appeal before the Tribunal on the following grounds : "1.Because in any view, th

Section 143(3)Section 147Section 148Section 250Section 69

relevant assessment year 2012-13 and after obtaining the sanction from PCIT, Central Bhopal, notice u/s. 148 was issued and served upon the assessee. Reasons recorded were also provided to the assessee during the cOurse of assessment proceedings. In response to notice u/s. 148 of the Act, assessee filed return

Ratanvav Juth Vividh Karyakari Sahakari Mandali Limited, Bhavnagar, Gujarat vs. ITO Ward 1(8) Bhavnagar, Bhavnagar, Gujarat

In the result, the appeal of the assessee is allowed

ITA 105/AHD/2026[2018-19]Status: DisposedITAT Ahmedabad21 Apr 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Years: 2018-19

Section 139(1)Section 147Section 148Section 148ASection 80PSection 80P(2)(a)Section 80P(2)(d)

addition was made in the assessment and CIT(A) order by disallowing deduction claimed u/s 80P. No addition can be made other than for reasons recorded while issuing notice u/s 148A and when reasons to re-open ceases to survive. 6. Shri Chetan Agarwal, the Ld. AR of the assessee ... claimed u/s. 80P of the Act. The Ld. AR submitted that no addition could have been made by the AO other than for the reason recorded by the AO for issue of notice u/s. 148 of the Act. Therefore, the Ld. CIT(A) was not correct in sustaining the disallowance

ITO 19.3.1, Mumbai vs. Sourabh Navalkishor Garg, Mumbai

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5804/MUM/2025[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

noticed that DCIT, Central Circle 7(3), Mumbai has reopened the case for the year by issuing notice u/s 148 on 28-03-2016. Reasons recorded for reopening the case is same that of ACIT, Circle 2, Ajmer. It is noticed from assessment order dt 20-12-2016 passed

Vaibhav Reality Development Limited, Vadodara vs. The Income Tax Officer, Ward-2(1)(1) (Old Ward-2(1)(4)), Vadodara

In the result, the appeal of the asessee is allowed in above terms

ITA 1325/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad21 Apr 2026AY 2014-15
For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri Alpesh Parmar, CIT. DR
Section 133ASection 143(1)Section 143(3)Section 144Section 147(2)(b)Section 148Section 250Section 44A

u/s.148 of the Act was issued to the assessee in response to which no return of income was filed by the assessee. Copy of reasons recorded by the AO for reopening of the case of the assessee were also supplied to the assessee and several notices were issued ... relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer, that it is a fit case for the issue of such notice. (2) In a case other than a case falling under sub-section

ITO 19.3.1, Mumbai vs. Sourabh Navalkishor Garg, Mumbai

In the result the appeals filed by the revenue for both years under consideration stands dismissed

ITA 5803/MUM/2025[2009-10]Status: DisposedITAT Mumbai21 Apr 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 37Section 68Section 74

noticed that DCIT, Central Circle 7(3), Mumbai has reopened the case for the year by issuing notice u/s 148 on 28-03-2016. Reasons recorded for reopening the case is same that of ACIT, Circle 2, Ajmer. It is noticed from assessment order dt 20-12-2016 passed

M. Abbas & Co., Mumbai vs. ACIT 24(2), Mumbai

ITA 1224/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Apr 2026AY 2009-10

Bench: Hon’Ble Justice (Retd.) C V Bhadang& Shri Arun Khodpia, Am

For Appellant: Shri Vipul Josshi, AdvFor Respondent: Assessee by
Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 28Section 69C

thereof were not satisfied. 4.3 Without prejudice to the generality of the above grounds, the reassessment is bad in law as- (i)The actual reasons recorded before issuing the notice u/s 148 of the Act were not supplied; (ii)The basic condition of having 'reason to believe that income chargeable ... initiating re-assessment and completion thereof were not satisfied. 7. To establish the aforesaid legal ground, ld. AR raised a contention that the actual reasons recorded before issuing the notice u/s 148 of the Act were not supplied to the assessee. The basic condition for having reason to believe that

Parmanand, Agra vs. ITO, Ward, 2(1)(2), Agra

In the result, assessee’s appeal is allowed

ITA 447/AGR/2025[2015-16]Status: DisposedITAT Agra17 Apr 2026AY 2015-16
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 250Section 69C

made u/s 69C r.w.s 115BBE is also wrong, bad in law, without Jurisdiction as on perusal of the Show Cause Notice issued, the reasons recorded (though not provided) perhaps are for disallowance u/s 40A(3) of the I.T. Act whereas in the Assessment order the addition has been made ... This is apparently bad in law and not permissible under the Act. Reasons recorded have to be read as it is. No substitution/deletion/addition in the reasons recorded is permissible under the law. On this ground also the addition deserves to be deleted. 3 | P a g e 5. That

Govind Sharma, Mathura vs. ITO, Ward 1(3)(1), Mathura

In the result, the assessee’s appeal is allowed

ITA 428/AGR/2025[2015-16]Status: DisposedITAT Agra17 Apr 2026AY 2015-16
Section 10(38)Section 147Section 148Section 151Section 250Section 68

containing 100 pages. The said approval in question is endorsed on the proforma dated 31.03.2021 against column No. 1, which states “in view of reasons recorded by ld A.O, I am satisfied that income has escaped 3 | P a g e assessment. It is therefore, a fit case for issue ... relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer, that it is a fit case for the issue of such notice. (2) In a case other than a case falling under sub-section

Amrapar Seva Sahkari Mandli Ltd, Amrapar vs. The Principal Commissioner of Income Tax - 1, Rajkot

In the result, the appeal of the assessee is dismissed

ITA 324/RJT/2025[2018-19]Status: DisposedITAT Rajkot17 Apr 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 324/Rjt/2025 Assessment Year: (2018-19) Amrapar Seva Sahkari Mandali Ltd. Vs. The Principal Commissioner Of C/O., Sarda & Sarda, Sakar, 1St Floor, Income Tax – 1, Dr. Radha Krishna Road, Opp. Aayakar Bhavan, Race Course Rajkumar Collage, Rajkot - 360001 Ring Road, Rajkot – 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaaa0819N (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar : Shri Sanjay Punglia, Ld. Cit(Dr) Respondent By Date Of Hearing : 18/03/2026 : 17/04/2026 Date Of Pronouncement

For Appellant: Shri Vimal Desai, Ld. AR
Section 139(1)Section 147Section 148Section 263Section 80ASection 80PSection 80P(2)(d)

order, passed by the AO u/s. 147 r.w.s. 144B and directing a de-novo assessment on an issue that was never part of the reasons recorded for reopening. 4. The Ld. PCIT has exceeded jurisdiction by setting aside the reassessment order on an issue unrelated to the reason recorded ... note that the assessing officer could not make addition on other grounds which did not form part of the reasons recorded by the assessing officer, for that, reliance is placed on the judgement of Hon’ble Gujarat High Court in the case of CIT Vs. Mohmed Juned Dadani

Shri Sandip Harkishan Marwadi, Rajkot vs. The ACIT, Circle-1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 164/RJT/2023[2009-10]Status: DisposedITAT Rajkot17 Apr 2026AY 2009-10

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 164/Rjt/2023 "नधा"रणवष" / Assessment Year: (2009-10) (Hybrid Hearing) Sandip Harkishan Marwadi Vs. Assistant Commissioner Of C/O. Sarda & Sarda, Cas, Income Tax, Circle - 2(1), 1St Floor, "Sakar", Income Tax Office, Racecourse Dr. Radhakrishnan Road, Road, Sadar, Rajkot - 360001. Opp. Rajkumar College, Gujarat Rajkot-360001,(Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adbpm1302R (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 26 / 03 /2026 Date Of Pronouncement : 17/ 04 /2026

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 148Section 250

raised by the assessee, challenging the reopening of the assessment. The ld.Counsel pointed out that there is no whisper in the reasons recorded, of any tangible material which came to the possession of the assessing officer. It reflects an arbitrary exercise of the power conferred under section ... assessing officer was not having any material information to form "a reason to believe" that there was an escapement of income. In the reasons recorded there is complete non-application of mind and reasons were not recorded with reference to the assessee under consideration and in the reasons recorded

Jagdishprasad Maheshwari, Nagpur vs. DCIT/ACIT Circle-4, Nagpur

In the result, appeal of the assessee is allowed

ITA 748/NAG/2025[2013-14]Status: DisposedITAT Nagpur17 Apr 2026AY 2013-14

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.748/Nag/2025 Assessment Year : 2013-14 Jagdishprasad Maheshwari Vs. Dcit/Acit, Circle-4, C/O Surgical India, Nagpur Shop No. 214,215,224,225, Sandesh Dawa Bazar, Near Haj House, Ganjipeth, Nagpur-440018, Maharashtra Pan: Acypm9289M Appellant Respondent

For Appellant: Shri Mahavir AtalFor Respondent: Shri Surjit Kumar Saha
Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 148

also the assessee had given money to the associations for conducting of conference. All these three issues have been referred in the reasons recorded for reopening. There is no other reference of any independent material gathered by the Assessing Officer which was not placed by the assessee during the course ... assessment proceedings. All the contents of reasons recorded are taken from the books of account and assessment records which already stood examined by the Assessing Officer in the assessment proceedings u/s.143(3) of the Act. It has been consistently held that in the case of completed assessment u/s.143

Sudheer Parimala, Hyderabad vs. Income Tax Officer, Ward-10(1), Hyderabad

In the result, the appeal filed by the assessee is allowed

ITA 758/HYD/2025[2015-16]Status: DisposedITAT Hyderabad17 Apr 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.758/Hyd./2025 Assessment Year 2015-2016 Sudheer Parimala, The Income Tax Officer, Hyderabad – 500 016. Vs. Ward-10(1), Hyderabad. Pan Ahppp7572E Pin - 500 004. Telangana (Appellant) (Respondent) For Assessee : Ca Kranthi Palivela & Ca Mrudulatha For Revenue : Dr. Sachin Kumar, Sr. Ar Date Of Hearing : 24.03.2026 Date Of Pronouncement : 17.04.2026 आदेश/Order

For Appellant: CA Kranthi Palivela And CA MrudulathaFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 147Section 271(1)(c)Section 44ASection 69A

satisfied that the second issue raised by the petitioner is also required to be answered in the affirmative. 21. Therefore, for the reasons recorded hereinabove, the proceedings initiated under Section 148 of the Act for reopening of the assessment relating to the Assessment Year 2017-18 are barred by limitation

Preeti Gupta, Hyderabad vs. DCIT., Circle - 9(1), I.T. Towers, Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 1175/HYD/2025[2014-15]Status: DisposedITAT Hyderabad17 Apr 2026AY 2014-15

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1174 & 1175/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15) Smt. Preeti Gupta Vs. Dy. Cit Hyderabad Circle 9(1) Pan: Abmpm7172Q Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/04/2026 घोषणा की तारीख/Pronouncement: 17/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri Madhukar Aves, Sr. AR
Section 111ASection 144BSection 147Section 148Section 151ASection 69A

quashed. 2. On the facts and circumstances of the case, the reassessment has been initiated on incorrect and inappropriate facts, as the reasons recorded allege non- disclosure of share transactions despite the appellant having duly disclosed short term capital gains of Rs.10,43,677/- on sale of shares

Preeti Gupta, Hyderabad vs. DCIT., Circle - 9(1), I.T. Towers, Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 1174/HYD/2025[2013-14]Status: DisposedITAT Hyderabad17 Apr 2026AY 2013-14

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1174 & 1175/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15) Smt. Preeti Gupta Vs. Dy. Cit Hyderabad Circle 9(1) Pan: Abmpm7172Q Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/04/2026 घोषणा की तारीख/Pronouncement: 17/04/2026 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri Madhukar Aves, Sr. AR
Section 111ASection 144BSection 147Section 148Section 151ASection 69A

quashed. 2. On the facts and circumstances of the case, the reassessment has been initiated on incorrect and inappropriate facts, as the reasons recorded allege non- disclosure of share transactions despite the appellant having duly disclosed short term capital gains of Rs.10,43,677/- on sale of shares

Snehalatha Singhi, Bangalore vs. DCIT, Circle-1(1)(2), Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 1175/BANG/2025[2012-13]Status: DisposedITAT Bangalore17 Apr 2026AY 2012-13

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2012-13

For Respondent: Shri K R Pradeep, Advocate &
Section 143(3)Section 147Section 148Section 234ASection 68Section 69C

show cause notice issued. Thereafter the AO generated the 143(2) notice on 23/12/2019 and the AO had also furnished the copy of the reasons recorded for initiating proceedings u/s. 148 of the Act on 24/12/2019. 5. Again another show cause notice was issued on 24/12/2019 granting time upto 27/12/2019

Rohan Hemant Thakkar, Mumbai vs. Income Tax Officer 22 3 2, Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 7105/MUM/2025[2011 - 2012]Status: DisposedITAT Mumbai17 Apr 2026

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm Mr. Rohan Hemant Thakkar, Income Tax Officer 22(3)(2), A 804 Prayog Building Wing A Kautilya Bhavan, Opposite Galaxy Hotel Prabhat Colony Bandra Kurla Complex, Vs. Road No.2 Bandra East, Santacruz East, Mumbai – 400 051 Mumbai – 400 055 Pan:Agnpt4221D (Appellant) : (Respondent)

For Respondent: Shri Annavaram Kosuri, Sr. AR
Section 143(1)Section 143(2)Section 143(3)Section 148Section 234ASection 250Section 54F

basis of mere change of opinion and in absence of any new tangible material in possession of Assessing Officer, (b) In the reason recorded the learned Assessing Officer himself admitted that notice under section 148 of the Act is issued on the basis of “ON VERIFICATION OF RECORD ... reasons recorded are not valid one as same are undated (d) The learned Assessing Officer erred in recording in reason that there is failure on the part of appellant to disclose fully and truly all material facts necessary for assessment. 04. The Hon’ble Commissioner of Income tax – Appeals erred

Income Tax Officer, Ward-5(1), Kolkata vs. M/S. Faithful Traders Private Limited, Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 2177/KOL/2024[2012-13]Status: DisposedITAT Kolkata17 Apr 2026AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 250

failed to prove the genuineness of the transactions. 2. That the Hon hie CIT(A) has erred in coming to the conclusion that the reasons recorded by the AO are mechanically done and lacks objective satisfaction. 3. That on the facts in absence of verification

Assistant Commissioner of Income Tax, Central Circle, Vapi vs. Rajeshbhai Maganbhai Ahir, Surat

In the result, the appeal filed by the Revenue is dismissed

ITA 1329/SRT/2024[2017-18]Status: DisposedITAT Rajkot15 Apr 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Ajay Uke, Sr.DRFor Respondent: Shri Hardik Vora, AR
Section 133ASection 143(3)Section 147Section 148Section 292Section 698Section 69ASection 69B

assessee had only made advance payments through proper banking channels, with the first installment being paid on 04.04.2017. Therefore, it was argued that the reasons recorded for reopening were based on incorrect facts and assumptions, and consequently the reassessment proceedings initiated on such grounds are liable to be quashed

Assistant Commissioner of Income Tax, Central Circle, Vapi vs. Rajeshbhai Maganbhai Ahir, Surat

In the result, the appeal filed by the Revenue is dismissed

ITA 1329/SRT/2024[2017-18]Status: DisposedITAT Surat15 Apr 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Ajay Uke, Sr.DRFor Respondent: Shri Hardik Vora, AR
Section 133ASection 143(3)Section 147Section 148Section 292Section 698Section 69ASection 69B

assessee had only made advance payments through proper banking channels, with the first installment being paid on 04.04.2017. Therefore, it was argued that the reasons recorded for reopening were based on incorrect facts and assumptions, and consequently the reassessment proceedings initiated on such grounds are liable to be quashed