1. Under the new regime reopening is based on Information flagged by risk management strategy & not reasons to believe

2. 148A – mandates AO to enquire about information before issuing of notice u/s 148

3. The word used u/s 148A if required (at the end) suggests that where the information is factually not correct, such cases need to be enquired

4. Opportunity should be given to reply as to why an inquiry should not be made about escapement of assessment – reply within 30 days

5. AO is required to take prior approval before passing order u/s 148A

6. Failure on the part of the assesses to disclose true and complete material facts has been done away with

7. Under the new regime possession of evidence must reveal income chargeable to tax which represents in the form of assets has escaped assessment with an amount > 50 lacs to reopen beyond 3 years.

8. 148A (d) order stating it is Fit case or not might work on the same principle as reasons to believe

9. Now AO will have to give subjective decisions on basis of objective information u/s 148A