https://www.taxtmi.com/caselaws?id=210573 The Court quashed the notice for reopening the assessment under Section 148 of the Income Tax Act, ruling in favor of the Petitioner. The Court found that there was no failure on the Petitioner's part to disclose material facts fully and truly, and the jurisdictional conditions for reopening the assessment beyond four years were not met. The Petitioner's challenge against the validity of the certificate issued under Section 195(2) versus Section 197 was upheld, clarifying that the certificate was indeed issued under Section 195(2). The Petition was allowed, and the rule was made absolute, with no order as to costs. en-us Tue, 24 Jan 2012 00:00:00 +0530 Tue, 29 May 2012 15:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210573 The Court quashed the notice for reopening the assessment under Section 148 of the Income Tax Act, ruling in favor of the Petitioner. The Court found that there was no failure on the Petitioner's part to disclose material facts fully and truly, and the jurisdictional conditions for reopening the assessment beyond four years were not met. The Petitioner's challenge against the validity of the certificate issued under Section 195(2) versus Section 197 was upheld, clarifying that the certificate was indeed issued under Section 195(2). The Petition was allowed, and the rule was made absolute, with no order as to costs. Case-Laws Income Tax Tue, 24 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210573