https://www.taxtmi.com/caselaws?id=64114 Reassessment under the Income-tax Act could not be sustained where the assessee had already disclosed all material facts and the issue of assessment capacity had been examined on the original record, making the reopening a mere change of opinion. The later enlargement of the limitation period was held inapplicable to the assessment year in question, and the Department could not rely on a prior appellate order to overcome the limitation bar. As no new material emerged, the reassessment was treated as not properly initiated and the challenge to reopening and limitation succeeded. en-us Fri, 17 Feb 1978 00:00:00 +0530 Thu, 03 Feb 2011 18:32:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64114 Reassessment under the Income-tax Act could not be sustained where the assessee had already disclosed all material facts and the issue of assessment capacity had been examined on the original record, making the reopening a mere change of opinion. The later enlargement of the limitation period was held inapplicable to the assessment year in question, and the Department could not rely on a prior appellate order to overcome the limitation bar. As no new material emerged, the reassessment was treated as not properly initiated and the challenge to reopening and limitation succeeded. Case-Laws Income Tax Fri, 17 Feb 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64114