https://www.taxtmi.com/caselaws?id=219103 The Tribunal upheld the CIT(A)'s decision to annul the reassessment proceedings, emphasizing that the reassessment was based on a change of opinion and that there was no failure on the part of the assessee to disclose fully and truly all material facts. The appeals filed by the revenue were dismissed, affirming that the initiation of reassessment proceedings was invalid both on the grounds of change of opinion and the applicability of the proviso to Section 147. en-us Fri, 27 Jan 2012 00:00:00 +0530 Thu, 22 Nov 2012 15:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219103 The Tribunal upheld the CIT(A)'s decision to annul the reassessment proceedings, emphasizing that the reassessment was based on a change of opinion and that there was no failure on the part of the assessee to disclose fully and truly all material facts. The appeals filed by the revenue were dismissed, affirming that the initiation of reassessment proceedings was invalid both on the grounds of change of opinion and the applicability of the proviso to Section 147. Case-Laws Income Tax Fri, 27 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219103