https://www.taxtmi.com/caselaws?id=69231 The Tribunal held that the reopening of assessments under section 147(a) was not valid as the Income Tax Officer's decision was based on incorrect grounds and a change of opinion without new material facts. The Tribunal emphasized the importance of reasonable grounds for reassessment and the need for the ITO to base reassessment on facts disclosed during the original assessment process. Consequently, the reassessments were set aside, and both appeals were allowed. en-us Thu, 05 Jan 1978 00:00:00 +0530 Tue, 05 Apr 2011 18:37:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69231 The Tribunal held that the reopening of assessments under section 147(a) was not valid as the Income Tax Officer's decision was based on incorrect grounds and a change of opinion without new material facts. The Tribunal emphasized the importance of reasonable grounds for reassessment and the need for the ITO to base reassessment on facts disclosed during the original assessment process. Consequently, the reassessments were set aside, and both appeals were allowed. Case-Laws Income Tax Thu, 05 Jan 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69231