https://www.taxtmi.com/caselaws?id=256332 The court held that the reopening of the assessment was not justified as there was no failure on the part of the petitioner to disclose all material facts necessary for assessment. The reasons for reopening did not reveal any new undisclosed material. The court found the reopening was based on a mere change of opinion and initiated at the suggestion of another authority, which was impermissible. Citing precedent, the court emphasized the necessity for evidence to support reopening reasons. Consequently, the court ruled in favor of the petitioner, quashing and setting aside the notice issued under section 148 of the Income Tax Act. en-us Mon, 05 Jan 2015 00:00:00 +0530 Mon, 01 Jun 2026 12:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256332 The court held that the reopening of the assessment was not justified as there was no failure on the part of the petitioner to disclose all material facts necessary for assessment. The reasons for reopening did not reveal any new undisclosed material. The court found the reopening was based on a mere change of opinion and initiated at the suggestion of another authority, which was impermissible. Citing precedent, the court emphasized the necessity for evidence to support reopening reasons. Consequently, the court ruled in favor of the petitioner, quashing and setting aside the notice issued under section 148 of the Income Tax Act. Case-Laws Income Tax Mon, 05 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256332