https://www.taxtmi.com/caselaws?id=77151 The court held that the notice issued under section 148 of the Income-tax Act, 1961, to reopen the assessment was beyond the statutory period of four years. It was found that there was no failure or omission on the part of the petitioner, as all relevant details had been provided during the original assessment. The court determined that the notice was merely a change of opinion on the same facts and ruled in favor of the petitioner, quashing the notice and allowing the petition with no costs. en-us Tue, 17 Mar 2009 00:00:00 +0530 Sat, 02 Feb 2013 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=77151 The court held that the notice issued under section 148 of the Income-tax Act, 1961, to reopen the assessment was beyond the statutory period of four years. It was found that there was no failure or omission on the part of the petitioner, as all relevant details had been provided during the original assessment. The court determined that the notice was merely a change of opinion on the same facts and ruled in favor of the petitioner, quashing the notice and allowing the petition with no costs. Case-Laws Income Tax Tue, 17 Mar 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=77151