https://www.taxtmi.com/caselaws?id=236532 The tribunal held that the reassessment proceedings were invalid as they were based on a change of opinion without new facts or evidence, rendering the reassessment notice under Section 148 issued without jurisdiction. Consequently, the appeal filed by the assessee was allowed, while the appeal filed by the AO was dismissed. The tribunal emphasized the necessity of tangible material for reopening assessments and the prohibition against reassessment solely based on a change of opinion. en-us Wed, 03 Jul 2013 00:00:00 +0530 Sat, 31 Aug 2013 08:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236532 The tribunal held that the reassessment proceedings were invalid as they were based on a change of opinion without new facts or evidence, rendering the reassessment notice under Section 148 issued without jurisdiction. Consequently, the appeal filed by the assessee was allowed, while the appeal filed by the AO was dismissed. The tribunal emphasized the necessity of tangible material for reopening assessments and the prohibition against reassessment solely based on a change of opinion. Case-Laws Income Tax Wed, 03 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236532