https://www.taxtmi.com/caselaws?id=122777 The Tribunal held that the reopening of assessments for the years 1995-96 and 1996-97 was invalid as it was based on a mere change of opinion regarding the tax rate applied, not on undisclosed income. However, for the assessment year 1997-98, the reopening was deemed valid as the Assessing Officer had reason to believe the assessee was taxed at a lower rate. The application of a higher tax rate for foreign companies was considered justified for 1997-98 under the Explanation to Section 90(2). The revenue's appeals for 1995-96 and 1996-97 were partly allowed, while the appeal for 1997-98 was allowed. en-us Fri, 16 Oct 2009 00:00:00 +0530 Fri, 17 Aug 2012 11:40:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122777 The Tribunal held that the reopening of assessments for the years 1995-96 and 1996-97 was invalid as it was based on a mere change of opinion regarding the tax rate applied, not on undisclosed income. However, for the assessment year 1997-98, the reopening was deemed valid as the Assessing Officer had reason to believe the assessee was taxed at a lower rate. The application of a higher tax rate for foreign companies was considered justified for 1997-98 under the Explanation to Section 90(2). The revenue's appeals for 1995-96 and 1996-97 were partly allowed, while the appeal for 1997-98 was allowed. Case-Laws Income Tax Fri, 16 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122777