https://www.taxtmi.com/caselaws?id=68657 The Tribunal upheld the CIT(A)'s decision to quash reassessment proceedings, ruling that the second notice under section 148 of the IT Act, 1961, was unjustified as it was based on the same facts considered in the initial assessment. The reassessment was deemed a change of opinion by the Assessing Officer, which is impermissible under the law. The appeal by the Revenue was dismissed, affirming the legality of setting aside the assessment order dated 28th March, 2003, emphasizing the limitations on the AO's power to initiate reassessment solely on a change of opinion. en-us Fri, 16 Jun 2006 00:00:00 +0530 Wed, 08 Aug 2012 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=68657 The Tribunal upheld the CIT(A)'s decision to quash reassessment proceedings, ruling that the second notice under section 148 of the IT Act, 1961, was unjustified as it was based on the same facts considered in the initial assessment. The reassessment was deemed a change of opinion by the Assessing Officer, which is impermissible under the law. The appeal by the Revenue was dismissed, affirming the legality of setting aside the assessment order dated 28th March, 2003, emphasizing the limitations on the AO's power to initiate reassessment solely on a change of opinion. Case-Laws Income Tax Fri, 16 Jun 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=68657