https://www.taxtmi.com/caselaws?id=204715 The court ruled in favor of the petitioner, an assessee under the Income Tax Act, in a challenge against a notice issued under Section 147 for re-opening assessment beyond four years. The court held that the notice was unsustainable as there was no failure to disclose material facts necessary for assessment, emphasizing that Section 147 does not allow correcting an incorrect assessment without such failure being recorded. Consequently, the court quashed the notice, allowed the writ petition, and ordered the issuance of a writ of Certiorari to quash the notice and reassessment proceedings for the relevant assessment year, along with a writ of Prohibition to prevent further action based on the impugned notice. en-us Thu, 09 Jun 2011 00:00:00 +0530 Sat, 16 May 2026 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204715 The court ruled in favor of the petitioner, an assessee under the Income Tax Act, in a challenge against a notice issued under Section 147 for re-opening assessment beyond four years. The court held that the notice was unsustainable as there was no failure to disclose material facts necessary for assessment, emphasizing that Section 147 does not allow correcting an incorrect assessment without such failure being recorded. Consequently, the court quashed the notice, allowed the writ petition, and ordered the issuance of a writ of Certiorari to quash the notice and reassessment proceedings for the relevant assessment year, along with a writ of Prohibition to prevent further action based on the impugned notice. Case-Laws Income Tax Thu, 09 Jun 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204715