https://www.taxtmi.com/caselaws?id=254593 The court quashed the notice and reassessment order as the assumption of jurisdiction under Sections 147 and 148 of the Income Tax Act was found to be ultra vires. The court held that the notice was issued beyond the permissible period, lacked specific allegations of non-disclosure, and constituted a mere change of opinion by the Assessing Officer. Additionally, the rushed issuance of the reassessment order violated principles of natural justice. The court exercised its extraordinary jurisdiction, allowing the petition and making no order as to costs. en-us Mon, 22 Dec 2014 00:00:00 +0530 Sat, 16 May 2026 12:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=254593 The court quashed the notice and reassessment order as the assumption of jurisdiction under Sections 147 and 148 of the Income Tax Act was found to be ultra vires. The court held that the notice was issued beyond the permissible period, lacked specific allegations of non-disclosure, and constituted a mere change of opinion by the Assessing Officer. Additionally, the rushed issuance of the reassessment order violated principles of natural justice. The court exercised its extraordinary jurisdiction, allowing the petition and making no order as to costs. Case-Laws Income Tax Mon, 22 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=254593