https://www.taxtmi.com/caselaws?id=218997 The ITAT dismissed the Revenue's appeal, upholding the CIT(A)'s decision to quash the reassessment proceedings. The ITAT found that the AO's reopening of the assessment was based on a mere change of opinion without any new material, and there was no failure on the part of the assessee to disclose all material facts. Consequently, the notice under Section 148 was deemed invalid, and the disallowance of depreciation on goodwill was not justified. en-us Fri, 20 Jul 2012 00:00:00 +0530 Fri, 14 Sep 2012 15:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218997 The ITAT dismissed the Revenue's appeal, upholding the CIT(A)'s decision to quash the reassessment proceedings. The ITAT found that the AO's reopening of the assessment was based on a mere change of opinion without any new material, and there was no failure on the part of the assessee to disclose all material facts. Consequently, the notice under Section 148 was deemed invalid, and the disallowance of depreciation on goodwill was not justified. Case-Laws Income Tax Fri, 20 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218997