https://www.taxtmi.com/caselaws?id=251759 The High Court held that the Assessing Officer had formed an opinion during the initial assessment that the gifts were genuine, making the reopening based on a change of opinion without jurisdiction. The Court emphasized that even minimal inquiry during the initial assessment indicated opinion formation, rendering the assessment not amenable to reopening under Section 148 of the Income Tax Act. Both petitions were allowed, setting aside the notices dated 31st March, 2006, with no costs awarded. en-us Wed, 27 Aug 2014 00:00:00 +0530 Sun, 28 Sep 2014 06:15:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251759 The High Court held that the Assessing Officer had formed an opinion during the initial assessment that the gifts were genuine, making the reopening based on a change of opinion without jurisdiction. The Court emphasized that even minimal inquiry during the initial assessment indicated opinion formation, rendering the assessment not amenable to reopening under Section 148 of the Income Tax Act. Both petitions were allowed, setting aside the notices dated 31st March, 2006, with no costs awarded. Case-Laws Income Tax Wed, 27 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251759