https://www.taxtmi.com/caselaws?id=251866 The court held that the notice for reopening the assessment under Section 148 of the Income Tax Act was invalid as it was issued beyond the permissible period without any failure on the part of the assessee to disclose material facts. Additionally, the reassessment proceedings were deemed to be initiated due to a change of opinion by the Assessing Officer, which was not permissible. Consequently, the petition was allowed, and the notice under Section 148 was quashed. en-us Fri, 25 Jul 2014 00:00:00 +0530 Tue, 07 Apr 2026 11:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251866 The court held that the notice for reopening the assessment under Section 148 of the Income Tax Act was invalid as it was issued beyond the permissible period without any failure on the part of the assessee to disclose material facts. Additionally, the reassessment proceedings were deemed to be initiated due to a change of opinion by the Assessing Officer, which was not permissible. Consequently, the petition was allowed, and the notice under Section 148 was quashed. Case-Laws Income Tax Fri, 25 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251866