https://www.taxtmi.com/caselaws?id=233745 The court quashed the notice issued under Section 148 for reopening the assessment, dated 21.11.2011, for the Assessment Year 2007-2008. The court found the notice invalid as it was based on an audit objection without independent assessment by the Assessing Officer, indicating a lack of belief that income had escaped assessment. Additionally, the court held that reopening based on a change of opinion was impermissible, referencing precedents. The Assessing Officer's failure to independently apply his mind and the violation of procedural requirements led to the court allowing the petition with no order as to costs. en-us Thu, 28 Feb 2013 00:00:00 +0530 Thu, 24 Oct 2013 13:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233745 The court quashed the notice issued under Section 148 for reopening the assessment, dated 21.11.2011, for the Assessment Year 2007-2008. The court found the notice invalid as it was based on an audit objection without independent assessment by the Assessing Officer, indicating a lack of belief that income had escaped assessment. Additionally, the court held that reopening based on a change of opinion was impermissible, referencing precedents. The Assessing Officer's failure to independently apply his mind and the violation of procedural requirements led to the court allowing the petition with no order as to costs. Case-Laws Income Tax Thu, 28 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233745