https://www.taxtmi.com/caselaws?id=220521 The court held that the re-opening of the assessment under Section 147 of the Income Tax Act, 1961 constituted a mere change of opinion, which is impermissible in law. The court also ruled that the revenue audit personnel cannot comment on points of law, such as the interpretation of tax provisions. Consequently, the notice issued under Section 148 of the Act and all related proceedings were quashed and set aside, and the writ petition was allowed with no costs. en-us Tue, 22 Jan 2013 00:00:00 +0530 Tue, 29 Jan 2013 06:24:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220521 The court held that the re-opening of the assessment under Section 147 of the Income Tax Act, 1961 constituted a mere change of opinion, which is impermissible in law. The court also ruled that the revenue audit personnel cannot comment on points of law, such as the interpretation of tax provisions. Consequently, the notice issued under Section 148 of the Act and all related proceedings were quashed and set aside, and the writ petition was allowed with no costs. Case-Laws Income Tax Tue, 22 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220521