https://www.taxtmi.com/caselaws?id=214518 The court annulled the entire assessment due to the invalidity of the second reopening under sections 147/148 of the Income Tax Act, 1961, as it constituted impermissible change of opinion. The addition of Rs. 7,50,000 under section 2(22)(e) of the Income Tax Act, 1961, was also annulled, as the CIT(A)'s order was found to be flawed in both facts and law. The reassessment orders were annulled, and the additions made were deleted, resulting in the appeals of the assessees being allowed. en-us Thu, 31 May 2012 00:00:00 +0530 Sat, 30 Jun 2012 12:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214518 The court annulled the entire assessment due to the invalidity of the second reopening under sections 147/148 of the Income Tax Act, 1961, as it constituted impermissible change of opinion. The addition of Rs. 7,50,000 under section 2(22)(e) of the Income Tax Act, 1961, was also annulled, as the CIT(A)'s order was found to be flawed in both facts and law. The reassessment orders were annulled, and the additions made were deleted, resulting in the appeals of the assessees being allowed. Case-Laws Income Tax Thu, 31 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214518