https://www.taxtmi.com/caselaws?id=68987 The Appellate Tribunal ITAT MADRAS-A ruled in favor of the assessee, holding that the WTO lacked legal competence to reopen assessments based solely on a change of opinion without conducting necessary inquiries. The Tribunal emphasized the assessee's duty to disclose primary facts and the WTO's obligation to verify valuations independently. Additionally, the Tribunal dismissed the department's case for reassessment under section 17(1)(b) due to insufficient evidence and highlighted that a mere change of opinion does not warrant reassessment. The original assessments for the relevant years were confirmed, and the department's appeals were dismissed. en-us Wed, 26 Dec 1984 00:00:00 +0530 Mon, 04 Apr 2011 13:01:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=68987 The Appellate Tribunal ITAT MADRAS-A ruled in favor of the assessee, holding that the WTO lacked legal competence to reopen assessments based solely on a change of opinion without conducting necessary inquiries. The Tribunal emphasized the assessee's duty to disclose primary facts and the WTO's obligation to verify valuations independently. Additionally, the Tribunal dismissed the department's case for reassessment under section 17(1)(b) due to insufficient evidence and highlighted that a mere change of opinion does not warrant reassessment. The original assessments for the relevant years were confirmed, and the department's appeals were dismissed. Case-Laws Wealth-tax Wed, 26 Dec 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=68987