https://www.taxtmi.com/caselaws?id=76024 The court dismissed the appeals, affirming the Tribunal's decision that the invocation of Section 147 for reopening assessments was invalid. The court emphasized that the assessee had not failed to disclose material facts as the retrospective amendment imposing new conditions for deduction was not in place during the original assessments. It was deemed unreasonable to expect the assessee to anticipate such future changes. The decision highlighted the importance of factual basis for reopening assessments under Section 147 of the Income Tax Act, 1961. en-us Fri, 07 May 2010 00:00:00 +0530 Thu, 15 Mar 2012 16:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=76024 The court dismissed the appeals, affirming the Tribunal's decision that the invocation of Section 147 for reopening assessments was invalid. The court emphasized that the assessee had not failed to disclose material facts as the retrospective amendment imposing new conditions for deduction was not in place during the original assessments. It was deemed unreasonable to expect the assessee to anticipate such future changes. The decision highlighted the importance of factual basis for reopening assessments under Section 147 of the Income Tax Act, 1961. Case-Laws Income Tax Fri, 07 May 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=76024