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of <h1>Reassessment notice under ss. 147/148 for DTAA-based India income taxability struck down as impermissible change of opinion</h1> The dominant issue was the validity of a reassessment notice under ss. 147/148, where the reopening sought to reassess taxability of income alleged to ... Reassessment - Validity of notice issued under section 148 - taxability in respect of income accrued or deemed to accrue in India - double taxation avoidance agreement - HC held that, Since the Tribunal in the appeal relating to the assessee-company had considered the Tribunal's earlier decision in Boudier Christian's case, it will obviously amount to mere change of opinion, and hence the notice under section 147/148 would be illegal - HELD THAT:- We see no reason to interfere with the decision of the High Court [2000 (8) TMI 45 - ALLAHABAD HIGH COURT]. Accordingly, the civil appeals are dismissed with costs. The Supreme Court dismissed the civil appeals with costs after considering the facts and finding no reason to interfere with the decision of the High Court. (Supreme Court Citation: 2003 (1) TMI 101 - SC)
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