https://www.taxtmi.com/caselaws?id=248319 The High Court held that the reassessment proceedings under section 148 of the Income-tax Act, 1961 were invalid as they were based on a change in opinion rather than new and unexplored sources. The court emphasized that the Assessing Officer lacked the power to initiate proceedings solely on a change of opinion post the initial assessment under section 143(3) of the Act. The court applied the principles from CIT v. Kelvinator of India Ltd., highlighting that reassessment must be grounded on a valid reason to believe income has escaped assessment. Consequently, the court dismissed the appeal, affirming the Tribunal's decision in favor of the assessee. en-us Fri, 30 Aug 2013 00:00:00 +0530 Thu, 08 Jan 2015 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248319 The High Court held that the reassessment proceedings under section 148 of the Income-tax Act, 1961 were invalid as they were based on a change in opinion rather than new and unexplored sources. The court emphasized that the Assessing Officer lacked the power to initiate proceedings solely on a change of opinion post the initial assessment under section 143(3) of the Act. The court applied the principles from CIT v. Kelvinator of India Ltd., highlighting that reassessment must be grounded on a valid reason to believe income has escaped assessment. Consequently, the court dismissed the appeal, affirming the Tribunal's decision in favor of the assessee. Case-Laws Income Tax Fri, 30 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248319