https://www.taxtmi.com/caselaws?id=219364 The Tribunal and CIT(A) dismissed the Revenue's appeal challenging the reopening of assessment for the assessment year 2001-2002 under Sections 147 and 148 of the Income Tax Act, 1961. It was found that the reassessment proceedings were initiated based on a change of opinion, which was impermissible under the law. The failure to disclose the MERC circular was deemed irrelevant as it postdated the original assessment. The application of Section 80IA(10) was deemed inapplicable, and the reassessment was concluded to be unjustified, leading to the dismissal of the Revenue's appeal. en-us Mon, 26 Nov 2012 00:00:00 +0530 Wed, 12 Dec 2012 05:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219364 The Tribunal and CIT(A) dismissed the Revenue's appeal challenging the reopening of assessment for the assessment year 2001-2002 under Sections 147 and 148 of the Income Tax Act, 1961. It was found that the reassessment proceedings were initiated based on a change of opinion, which was impermissible under the law. The failure to disclose the MERC circular was deemed irrelevant as it postdated the original assessment. The application of Section 80IA(10) was deemed inapplicable, and the reassessment was concluded to be unjustified, leading to the dismissal of the Revenue's appeal. Case-Laws Income Tax Mon, 26 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219364