https://www.taxtmi.com/caselaws?id=217804 The court held that the reopening of assessments was not justified as the assessee had disclosed all primary facts necessary for assessment. The court quashed the notices issued under section 148, stating there was no failure to disclose material facts. It was clarified that the AO cannot reopen assessments based on a mere change of opinion without new tangible material. The petitions were allowed, and the reopening notices were set aside. en-us Fri, 16 Mar 2012 00:00:00 +0530 Fri, 26 Oct 2012 08:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217804 The court held that the reopening of assessments was not justified as the assessee had disclosed all primary facts necessary for assessment. The court quashed the notices issued under section 148, stating there was no failure to disclose material facts. It was clarified that the AO cannot reopen assessments based on a mere change of opinion without new tangible material. The petitions were allowed, and the reopening notices were set aside. Case-Laws Income Tax Fri, 16 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217804