Judgment B. P. Singh, Loknath Prasad, JJ. 1. Heard counsel for the parties. 2. The instant writ application has been preferred by the petitioner for quashing the notice issued under Sec.148 of the income-Tax Act, 1961, which is Annexure-3 to this application. The petitioner has been called upon to file return of Income-Tax for the assessment year 1990-91. The sole ground on-which the notice has been issued under Sec.148 of the Income Tax Act is challenged is that the assessing officer before issuing the notice has not recorded his reasons and, therefore, has improperly exercised his jurisdiction. It was submitted that unless reasons exist justifying issuance of notice under Sec.148 of the Income Tax Act, the income Tax Officer has no jurisdiction to issue such notice. 3. To satisfy ourselves, we required the Department to file a counter-affidavit and to produce the record before us. Accordingly, a counter-affidavit has been filed and the record produced. We may only observe that the notice does not disclose any reason, but that may not be necessary if reasons can be found recorded in the file by the assessing officer. It is also well settled that reasons must disclosed prima facie, facts which would justify issuance of the notice, and to any person perusing the reasons it should be obvious as to how the mind of the assessing officer worked when he Issued the notice. Such reasons must, therefore,- have particular reference to the case of the assessee, though it should not be in the form of a detailed judgment containing all the reasons and the justification for the same, but must objectively satisfy any person examining the order that the assessing officer has applied his mind to the facts of the case and has issued the notice. 4. In the instant case we find that in the file the assessing officer has recorded his reasons, and those reasons, have been quoted in paragraph no.6 of the counter-affidavit to the following effect : "i have reason to believe that the assessee has not disclosed fully and truly ell material facts necessary for his assessment. In the assessment year 1990-91 receipts chargable to tax has escaped assessment for the year under consideration. Action under section 147 has been initiated. Issue notice under Sec.148. " 5. In the assessment year 1990-91 receipts chargable to tax has escaped assessment for the year under consideration. Action under section 147 has been initiated. Issue notice under Sec.148. " 5. We are satisfied that the reasons disclosed in the file are not good enough reasons to justify issuance of notice under Sec.148 of the income Tax Act. The mere reproduction of the works of the section is not suflscient compliance with the requirement of Sec.148 of the Income tax Act. From a perusal of the reasons it is difficult to appreciate as to what was in the mind of the Income Tax Officer or what was the material on record which led him to believe that the assessee had not fully and truly disclosed all material facts necessary for assessment, and consequently receipts chargeable to tax had escaped assessment for the year. It is well settled that mere change of mind on the basis of same material, without anything else, is not sufficient justification for reopening an assessment and, therefore, the section requires that reasons must be recorded by the assessing officer. 6. We are, therefore, satisfied that the assessing officer acted improperly and without jurisdiction in issuing the notice under Sec.148 of the Income Tax Act and the same is, accordingly quashed, and any proceeding that may have been taken in pursuance thereof is also nullified. 7. This writ application is allowed to the extent indicated above, but this will not prevent the assessing officer from issuing a fresh notice in accordance with law, if circumstances so justify. Writ application allowed.