https://www.taxtmi.com/caselaws?id=258420 The court quashed the notice under Sections 147 and 148 of the Income Tax Act, finding it impermissible to reopen assessments based solely on a change of opinion. The petitioner had disclosed all relevant facts, including royalty payments, throughout the assessment process. The court emphasized the need for tangible material and a live link between reasons and belief for reopening assessments post-April 1989. As all facts were disclosed and considered by the authorities, the court allowed the writ petition, ruling in favor of the petitioner and quashing the notice and order in question. en-us Tue, 10 Mar 2015 00:00:00 +0530 Sat, 07 Nov 2015 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258420 The court quashed the notice under Sections 147 and 148 of the Income Tax Act, finding it impermissible to reopen assessments based solely on a change of opinion. The petitioner had disclosed all relevant facts, including royalty payments, throughout the assessment process. The court emphasized the need for tangible material and a live link between reasons and belief for reopening assessments post-April 1989. As all facts were disclosed and considered by the authorities, the court allowed the writ petition, ruling in favor of the petitioner and quashing the notice and order in question. Case-Laws Income Tax Tue, 10 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258420