https://www.taxtmi.com/caselaws?id=250915 The Tribunal upheld the CIT(A)'s decision, quashing the notice under Section 148 and subsequent assessment orders for two assessment years. The Tribunal found that the Assessing Officer lacked justification to reopen the assessment under Section 147 after four years, as there was no failure by the assessee to disclose all material facts. The Tribunal concluded that the reassessment was based on a change of opinion, not permissible under the law. The revenue's appeals were dismissed, affirming the original assessment orders. en-us Wed, 30 Apr 2014 00:00:00 +0530 Fri, 29 Aug 2014 08:30:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=250915 The Tribunal upheld the CIT(A)'s decision, quashing the notice under Section 148 and subsequent assessment orders for two assessment years. The Tribunal found that the Assessing Officer lacked justification to reopen the assessment under Section 147 after four years, as there was no failure by the assessee to disclose all material facts. The Tribunal concluded that the reassessment was based on a change of opinion, not permissible under the law. The revenue's appeals were dismissed, affirming the original assessment orders. Case-Laws Income Tax Wed, 30 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=250915