https://www.taxtmi.com/caselaws?id=259998 The Court quashed the notice for reopening the assessment under Section 148 of the Income Tax Act, finding it invalid as it was based on a change of opinion rather than a failure to disclose material facts. The Court emphasized that reassessment must be supported by tangible evidence of income escapement, not mere opinion changes. Additionally, the Court ruled that the assessee had complied with the requirement of full and true disclosure, and the Assessing Officer lacked jurisdiction to reopen the assessment after four years without evidence of non-disclosure. en-us Wed, 22 Apr 2015 00:00:00 +0530 Tue, 11 Aug 2015 12:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259998 The Court quashed the notice for reopening the assessment under Section 148 of the Income Tax Act, finding it invalid as it was based on a change of opinion rather than a failure to disclose material facts. The Court emphasized that reassessment must be supported by tangible evidence of income escapement, not mere opinion changes. Additionally, the Court ruled that the assessee had complied with the requirement of full and true disclosure, and the Assessing Officer lacked jurisdiction to reopen the assessment after four years without evidence of non-disclosure. Case-Laws Income Tax Wed, 22 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259998