Sec. 147 of Income Tax Act, 1961 — Reassessment - The Assessment Officer may start reassessment proceedings either because some fresh facts had come to light which were not previously disclosed or some information with regard to the facts previously disclosed comes into his possession which tends to expose the untruthfulness of those facts. In such situations, it is not a case of mere change of opinion or the drawing of a different inference from the same facts as were earlier available but acting on fresh information. Since the belief is that of the ITO, the sufficiency of reasons for forming this belief is not for the court to judge. Since in all these cases, there exists material to infer that income has escaped assessment, therefore, issuance of notice under Section 148 of the Act is based on such reasons as is permissible in law, therefore, reassessment notice itself cannot be set aside at this stage. Precision Vs. AADITYA CONSTRUCTION [2020] 427 ITR 198 (CHHATTISGARH)