https://www.taxtmi.com/caselaws?id=248359 The court ruled in favor of the petitioner, holding that the reopening notice under Section 148 of the Income Tax Act for the assessment year 2006-07 was impermissible as it was based on a mere change of opinion without any suppression of facts. The court also determined that the retrospective amendment to Section 80IA(4) by the Finance Act, 2009, did not justify the reassessment, as it was clarificatory and did not introduce new material for reassessment. Consequently, the court quashed the notices and consequential proceedings, emphasizing that the reassessment lacked valid grounds. en-us Wed, 09 Apr 2014 00:00:00 +0530 Tue, 10 Jun 2014 14:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248359 The court ruled in favor of the petitioner, holding that the reopening notice under Section 148 of the Income Tax Act for the assessment year 2006-07 was impermissible as it was based on a mere change of opinion without any suppression of facts. The court also determined that the retrospective amendment to Section 80IA(4) by the Finance Act, 2009, did not justify the reassessment, as it was clarificatory and did not introduce new material for reassessment. Consequently, the court quashed the notices and consequential proceedings, emphasizing that the reassessment lacked valid grounds. Case-Laws Income Tax Wed, 09 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248359