https://www.taxtmi.com/caselaws?id=247853 The petitioner challenged a notice under section 148 of the Income Tax Act 1961 issued more than four years after the relevant assessment year. The notice alleged non-deduction of tax on specific payments and wrongful deduction in respect of security transaction tax. The petitioner responded to queries raised by the Assessing Officer, providing detailed explanations and documentation. The court found the reassessment beyond the four-year period to be impermissible as it was based on a change in opinion rather than failure to disclose material facts, ruling in favor of the petitioner. en-us Fri, 25 Apr 2014 00:00:00 +0530 Sun, 25 May 2014 08:36:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247853 The petitioner challenged a notice under section 148 of the Income Tax Act 1961 issued more than four years after the relevant assessment year. The notice alleged non-deduction of tax on specific payments and wrongful deduction in respect of security transaction tax. The petitioner responded to queries raised by the Assessing Officer, providing detailed explanations and documentation. The court found the reassessment beyond the four-year period to be impermissible as it was based on a change in opinion rather than failure to disclose material facts, ruling in favor of the petitioner. Case-Laws Income Tax Fri, 25 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247853