https://www.taxtmi.com/caselaws?id=242913 The Tribunal dismissed the department's appeal and upheld the CIT (A)'s decision. The Tribunal found the notice issued under Section 148 read with Section 147 of the I.T. Act to be illegal, barred by limitation, and without jurisdiction. It concluded that the reopening of the assessment was based on a mere change of opinion, which is impermissible. The Tribunal allowed the assessee's application under Rule 27, citing that all material facts were disclosed during the original assessment. The department's grounds were deemed moot, and the original order was maintained. en-us Thu, 05 Dec 2013 00:00:00 +0530 Thu, 23 Jan 2014 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242913 The Tribunal dismissed the department's appeal and upheld the CIT (A)'s decision. The Tribunal found the notice issued under Section 148 read with Section 147 of the I.T. Act to be illegal, barred by limitation, and without jurisdiction. It concluded that the reopening of the assessment was based on a mere change of opinion, which is impermissible. The Tribunal allowed the assessee's application under Rule 27, citing that all material facts were disclosed during the original assessment. The department's grounds were deemed moot, and the original order was maintained. Case-Laws Income Tax Thu, 05 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242913