https://www.taxtmi.com/caselaws?id=217570 The Tribunal held that the reassessment proceedings initiated under Section 147 of the Income Tax Act were invalid as they were based on a mere change of opinion without new tangible material. The reassessment order was quashed, and the appeal by the assessee was allowed. The Tribunal emphasized that reassessment on the same material constitutes a change of opinion, not permissible under Section 147. The disallowances sustained by the CIT(A) in other grounds were not addressed due to the invalidity of the reassessment proceedings. en-us Tue, 31 Jul 2012 00:00:00 +0530 Thu, 18 Oct 2012 18:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217570 The Tribunal held that the reassessment proceedings initiated under Section 147 of the Income Tax Act were invalid as they were based on a mere change of opinion without new tangible material. The reassessment order was quashed, and the appeal by the assessee was allowed. The Tribunal emphasized that reassessment on the same material constitutes a change of opinion, not permissible under Section 147. The disallowances sustained by the CIT(A) in other grounds were not addressed due to the invalidity of the reassessment proceedings. Case-Laws Income Tax Tue, 31 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217570