It is common knowledge that Income Tax Department is very generous in case of issue of notice for reassessment u/s 148 is concerned. If senior official suggest an amendment or if an audit objection is raised or if an information , however vague it maybe, from its investigation wing is received or if the A.O himself is in doubt about an entry ………..he/she resort to proceedings u/s 148 . Legislature has put safeguards in form of approval mechanism from higher authorities like Joint CIT or Commissioner………..but fear psychosis paralyse the decision making capacity of the senior officer and often you will find that they casually sanction approval for issue of notice u/s 148 .
So what you do when you find that a reassessment notice is issued by the department despite the fact that the same issue was already considered in one assessment proceeding. Good news is that High Courts have entertained Writ petition gave relief to tax payers from harassment ! Shahrukh got one , so do you if issue matches.