https://www.taxtmi.com/caselaws?id=65647 The reassessment under section 147(a) was deemed invalid as all primary facts were disclosed during the original assessment. The notice under section 148 was considered a change of opinion and time-barred. Although the issue of limitation was found in favor of the revenue, it became academic due to the invalid reassessment. The appeal was allowed in part. en-us Thu, 03 Sep 1987 00:00:00 +0530 Fri, 18 Feb 2011 11:21:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65647 The reassessment under section 147(a) was deemed invalid as all primary facts were disclosed during the original assessment. The notice under section 148 was considered a change of opinion and time-barred. Although the issue of limitation was found in favor of the revenue, it became academic due to the invalid reassessment. The appeal was allowed in part. Case-Laws Income Tax Thu, 03 Sep 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65647