https://www.taxtmi.com/caselaws?id=71972 The Tribunal ruled in favor of the assessee, holding that the reassessment framed under section 148 of the Income Tax Act, 1961, based on a 'change of opinion' was not valid. The Tribunal emphasized that all necessary details were provided during the original assessment, and reopening the assessment on the same facts amounted to a change of opinion, which is impermissible in law. Additionally, the reassessment proceedings were deemed void and illegal as they were initiated within four years from the end of the relevant assessment year without any new material facts. The Revenue's appeal was dismissed, affirming the assessee's victory. en-us Fri, 18 Jul 2008 00:00:00 +0530 Tue, 07 Aug 2012 10:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71972 The Tribunal ruled in favor of the assessee, holding that the reassessment framed under section 148 of the Income Tax Act, 1961, based on a 'change of opinion' was not valid. The Tribunal emphasized that all necessary details were provided during the original assessment, and reopening the assessment on the same facts amounted to a change of opinion, which is impermissible in law. Additionally, the reassessment proceedings were deemed void and illegal as they were initiated within four years from the end of the relevant assessment year without any new material facts. The Revenue's appeal was dismissed, affirming the assessee's victory. Case-Laws Income Tax Fri, 18 Jul 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71972