https://www.taxtmi.com/caselaws?id=217258 The Tribunal condoned a 48-day delay in filing the appeal, attributing it to administrative procedures and officer transfers. The appeal was admitted for merits adjudication. Regarding the legality of reassessment proceedings under Sections 147 and 148 of the Income Tax Act, the Tribunal found the AO's reasons for reopening to be based on the same material as the original assessment, indicating a change of opinion rather than new evidence. The Tribunal concluded that the reassessment was void ab initio as it was initiated without any failure of disclosure by the assessee. The Revenue's appeal was dismissed. en-us Fri, 27 Jul 2012 00:00:00 +0530 Tue, 11 Sep 2012 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217258 The Tribunal condoned a 48-day delay in filing the appeal, attributing it to administrative procedures and officer transfers. The appeal was admitted for merits adjudication. Regarding the legality of reassessment proceedings under Sections 147 and 148 of the Income Tax Act, the Tribunal found the AO's reasons for reopening to be based on the same material as the original assessment, indicating a change of opinion rather than new evidence. The Tribunal concluded that the reassessment was void ab initio as it was initiated without any failure of disclosure by the assessee. The Revenue's appeal was dismissed. Case-Laws Income Tax Fri, 27 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217258