https://www.taxtmi.com/caselaws?id=220260 The court held that the respondent-Income Tax Officer's assumption of jurisdiction to reopen the assessment for Assessment Year 2005-2006 under sections 147 and 148 of the Income-tax Act was illegal. The court found that the reopening was not justified as there was no failure on the part of the assessee to disclose material facts, and it was based on a mere change of opinion, which is impermissible. Consequently, the notice dated 18.03.2011 was set aside, and the petition succeeded with no order as to costs. en-us Fri, 28 Sep 2012 00:00:00 +0530 Wed, 15 Apr 2026 14:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220260 The court held that the respondent-Income Tax Officer's assumption of jurisdiction to reopen the assessment for Assessment Year 2005-2006 under sections 147 and 148 of the Income-tax Act was illegal. The court found that the reopening was not justified as there was no failure on the part of the assessee to disclose material facts, and it was based on a mere change of opinion, which is impermissible. Consequently, the notice dated 18.03.2011 was set aside, and the petition succeeded with no order as to costs. Case-Laws Income Tax Fri, 28 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220260