https://www.taxtmi.com/caselaws?id=237553 The court ruled in favor of the petitioner, quashing the reassessment notice and order dated 28th September, 2010. The reassessment proceedings for the assessment year 2006-07 under Section 148 of the Income Tax Act were deemed invalid as they were based on a mere change of opinion by the Assessing Officer, without any new factual information emerging post the initial assessment order. The court emphasized the distinction between incorrect application of law and change of opinion, stating that reassessment should only occur in cases of the former, with Section 263 of the Act being the appropriate recourse for addressing errors in legal interpretation. en-us Mon, 05 Aug 2013 00:00:00 +0530 Mon, 30 Sep 2013 21:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237553 The court ruled in favor of the petitioner, quashing the reassessment notice and order dated 28th September, 2010. The reassessment proceedings for the assessment year 2006-07 under Section 148 of the Income Tax Act were deemed invalid as they were based on a mere change of opinion by the Assessing Officer, without any new factual information emerging post the initial assessment order. The court emphasized the distinction between incorrect application of law and change of opinion, stating that reassessment should only occur in cases of the former, with Section 263 of the Act being the appropriate recourse for addressing errors in legal interpretation. Case-Laws Income Tax Mon, 05 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237553