https://www.taxtmi.com/caselaws?id=69334 The Tribunal ruled in favor of the assessee, allowing the appeal against the reopening of assessment for the assessment year 1990-91 under section 147 of the Income-tax Act, 1961. The Tribunal held that the change in judicial interpretation by the Apex Court did not constitute a failure on the part of the assessee, emphasizing that compliance with the law as understood at the time of assessment should not be penalized due to subsequent developments. Therefore, the reopening based on the changed interpretation was deemed unjustified, leading to the reversal of the Commissioner (Appeals) order in favor of the assessee. en-us Mon, 12 Dec 2005 00:00:00 +0530 Mon, 17 Jun 2013 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69334 The Tribunal ruled in favor of the assessee, allowing the appeal against the reopening of assessment for the assessment year 1990-91 under section 147 of the Income-tax Act, 1961. The Tribunal held that the change in judicial interpretation by the Apex Court did not constitute a failure on the part of the assessee, emphasizing that compliance with the law as understood at the time of assessment should not be penalized due to subsequent developments. Therefore, the reopening based on the changed interpretation was deemed unjustified, leading to the reversal of the Commissioner (Appeals) order in favor of the assessee. Case-Laws Income Tax Mon, 12 Dec 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69334