https://www.taxtmi.com/caselaws?id=235322 The court held that the Department could not reopen an assessment done pursuant to directions under section 144A by issuing a notice under section 147/148. The court emphasized the binding effect of directions under section 144A on the Assessing Officer. As the Assessing Officer was attempting to reopen the assessment on the same ground as before the order under section 144A, it was considered a mere change of opinion. Since the Department did not find the order prejudicial, it could have invoked section 263. The impugned notice under section 148 was set aside and quashed, and all consequential proceedings were annulled. en-us Tue, 05 Apr 2011 00:00:00 +0530 Thu, 25 Jul 2013 14:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=235322 The court held that the Department could not reopen an assessment done pursuant to directions under section 144A by issuing a notice under section 147/148. The court emphasized the binding effect of directions under section 144A on the Assessing Officer. As the Assessing Officer was attempting to reopen the assessment on the same ground as before the order under section 144A, it was considered a mere change of opinion. Since the Department did not find the order prejudicial, it could have invoked section 263. The impugned notice under section 148 was set aside and quashed, and all consequential proceedings were annulled. Case-Laws Income Tax Tue, 05 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=235322