https://www.taxtmi.com/caselaws?id=220181 The court ruled in favor of the petitioner, quashing the notice for reopening the assessment under section 147 of the Income Tax Act, 1961. The court found that the reasons recorded did not provide jurisdiction to the Assessing Officer to reopen the assessment beyond the prescribed period. It was noted that the AO's observation of a mistake in calculation was not sufficient grounds for reopening, as there was no failure by the assessee to disclose material facts. The court held that the notice was invalid, deeming it a mere change of opinion, and ordered it to be set aside. en-us Mon, 05 Nov 2012 00:00:00 +0530 Sat, 29 Jun 2013 13:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220181 The court ruled in favor of the petitioner, quashing the notice for reopening the assessment under section 147 of the Income Tax Act, 1961. The court found that the reasons recorded did not provide jurisdiction to the Assessing Officer to reopen the assessment beyond the prescribed period. It was noted that the AO's observation of a mistake in calculation was not sufficient grounds for reopening, as there was no failure by the assessee to disclose material facts. The court held that the notice was invalid, deeming it a mere change of opinion, and ordered it to be set aside. Case-Laws Income Tax Mon, 05 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220181