https://www.taxtmi.com/caselaws?id=252090 The Bombay High Court allowed two petitions challenging notices under Section 148 of the Income Tax Act for reopening assessments for A.Y. 1999-2000 and 1998-1999. The Court held that the notices lacked jurisdictional validity due to a failure to disclose material facts and reliance on a CBDT circular, which was deemed a change of opinion without new material facts. Emphasizing the statutory requirement for issuing notices beyond the four-year period, the Court set aside the notices, citing the Topman Exports case to support the decision. The importance of independent reasonable belief by the Assessing Officer was highlighted, leading to the rejection of the objections and emphasizing adherence to statutory provisions in reopening assessments. en-us Wed, 17 Sep 2014 00:00:00 +0530 Thu, 19 Feb 2015 13:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252090 The Bombay High Court allowed two petitions challenging notices under Section 148 of the Income Tax Act for reopening assessments for A.Y. 1999-2000 and 1998-1999. The Court held that the notices lacked jurisdictional validity due to a failure to disclose material facts and reliance on a CBDT circular, which was deemed a change of opinion without new material facts. Emphasizing the statutory requirement for issuing notices beyond the four-year period, the Court set aside the notices, citing the Topman Exports case to support the decision. The importance of independent reasonable belief by the Assessing Officer was highlighted, leading to the rejection of the objections and emphasizing adherence to statutory provisions in reopening assessments. Case-Laws Income Tax Wed, 17 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252090