https://www.taxtmi.com/caselaws?id=79002 The court upheld the decision of the Commissioner of Income Tax (Appeals) to quash re-assessment proceedings for the Assessment Year 1996-1997 initiated under Section 147/148 of the Income Tax Act. The court found the re-assessment was based on a mere change of opinion, lacking valid grounds for initiation. Additionally, the court interpreted the first proviso to Section 147, emphasizing the time limit for reassessment. As the Assessing Officer failed to prove the assessee's failure to disclose material facts, the appeal was dismissed for lacking merit. en-us Mon, 20 Sep 2010 00:00:00 +0530 Wed, 29 Dec 2010 22:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=79002 The court upheld the decision of the Commissioner of Income Tax (Appeals) to quash re-assessment proceedings for the Assessment Year 1996-1997 initiated under Section 147/148 of the Income Tax Act. The court found the re-assessment was based on a mere change of opinion, lacking valid grounds for initiation. Additionally, the court interpreted the first proviso to Section 147, emphasizing the time limit for reassessment. As the Assessing Officer failed to prove the assessee's failure to disclose material facts, the appeal was dismissed for lacking merit. Case-Laws Income Tax Mon, 20 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=79002