https://www.taxtmi.com/caselaws?id=235289 The High Court dismissed the Revenue's appeal, affirming the Tribunal's decision. The Court held that the Assessing Officer's attempt to reopen the assessment based on previously examined issues was considered a change of opinion, which is impermissible. Additionally, the Court upheld the Tribunal's finding that specific provisions for Fringe Benefits Tax (FBT) under Section 115WG precluded the use of Section 148 for reopening assessments related to FBT. The decision emphasized that assessments must be based on new material or facts, not merely a change of opinion by the Assessing Officer. en-us Mon, 15 Apr 2013 00:00:00 +0530 Fri, 25 Oct 2013 17:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=235289 The High Court dismissed the Revenue's appeal, affirming the Tribunal's decision. The Court held that the Assessing Officer's attempt to reopen the assessment based on previously examined issues was considered a change of opinion, which is impermissible. Additionally, the Court upheld the Tribunal's finding that specific provisions for Fringe Benefits Tax (FBT) under Section 115WG precluded the use of Section 148 for reopening assessments related to FBT. The decision emphasized that assessments must be based on new material or facts, not merely a change of opinion by the Assessing Officer. Case-Laws Income Tax Mon, 15 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=235289