https://www.taxtmi.com/caselaws?id=213516 The High Court held that the notice issued under Section 148 of the Income Tax Act, 1961 for the assessment year 2005-06 was invalid. It was found that there was no change of opinion by the Assessing Officer and the assessee had fully disclosed all material facts during the original assessment. The court emphasized that the Assessing Officer had considered the royalty issue previously and the new officer's different interpretation did not indicate a failure to disclose facts. Consequently, the court quashed the notice, the order dismissing objections, and the re-assessment order, disposing of the writ petition without costs. en-us Mon, 14 May 2012 00:00:00 +0530 Tue, 22 May 2012 19:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213516 The High Court held that the notice issued under Section 148 of the Income Tax Act, 1961 for the assessment year 2005-06 was invalid. It was found that there was no change of opinion by the Assessing Officer and the assessee had fully disclosed all material facts during the original assessment. The court emphasized that the Assessing Officer had considered the royalty issue previously and the new officer's different interpretation did not indicate a failure to disclose facts. Consequently, the court quashed the notice, the order dismissing objections, and the re-assessment order, disposing of the writ petition without costs. Case-Laws Income Tax Mon, 14 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213516