Jayaram Paper Mills Ltd. vs Commissioner Of Income Tax "," Anr.

Whether the notice issued under section 148 of the Income Tax Act, 1961 for reopening assessment was valid when the Assessing Officer had reason to believe that income had escaped assessment due to the assessee's failure to disclose material facts fully and truly, and whether the reopening was merely a change of opinion --- Held No, the notice was valid as the Assessing Officer had prima facie material indicating escapement of income under Explanation 2 to section 147, and it was not a mere change of opinion.