https://www.taxtmi.com/caselaws?id=236547 The court held that the notice issued under Section 148 of the Income Tax Act, 1961, proposing reassessment for the Assessment Year 2005-06 was invalid as it was based on a change of opinion without fresh material. Additionally, the reassessment notice was barred by limitation as the petitioner had fully disclosed all material facts. The court quashed the notice and proceedings, emphasizing that reassessment cannot be solely based on a change of opinion. The writ petition was allowed with costs awarded to the petitioner. en-us Thu, 22 Aug 2013 00:00:00 +0530 Sat, 31 Aug 2013 08:28:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236547 The court held that the notice issued under Section 148 of the Income Tax Act, 1961, proposing reassessment for the Assessment Year 2005-06 was invalid as it was based on a change of opinion without fresh material. Additionally, the reassessment notice was barred by limitation as the petitioner had fully disclosed all material facts. The court quashed the notice and proceedings, emphasizing that reassessment cannot be solely based on a change of opinion. The writ petition was allowed with costs awarded to the petitioner. Case-Laws Income Tax Thu, 22 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236547