https://www.taxtmi.com/caselaws?id=237139 The court upheld the validity of the notice dated 3 May 2012 under Section 148 of the Income Tax Act, dismissing the petitioner's objections. The court found that the petitioner failed to disclose all material facts necessary for assessment, including the failure to file Form 3CEB, justifying the reassessment. Additionally, the court held that the Assessing Officer had a reasonable basis to believe that income had escaped assessment for the relevant year, based on adjustments made by the Transfer Pricing Officer for a subsequent year. The court concluded that there was no change of opinion by the Assessing Officer, affirming the validity of the reassessment notice. en-us Mon, 16 Sep 2013 00:00:00 +0530 Sat, 07 Dec 2013 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237139 The court upheld the validity of the notice dated 3 May 2012 under Section 148 of the Income Tax Act, dismissing the petitioner's objections. The court found that the petitioner failed to disclose all material facts necessary for assessment, including the failure to file Form 3CEB, justifying the reassessment. Additionally, the court held that the Assessing Officer had a reasonable basis to believe that income had escaped assessment for the relevant year, based on adjustments made by the Transfer Pricing Officer for a subsequent year. The court concluded that there was no change of opinion by the Assessing Officer, affirming the validity of the reassessment notice. Case-Laws Income Tax Mon, 16 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237139