https://www.taxtmi.com/caselaws?id=260572 The court held that the reassessment proceedings under Section 147 of the Income Tax Act were invalid as they were based on a mere change of opinion without any fresh material. The reassessment notice issued beyond four years was deemed without jurisdiction. Both the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal concluded that the reassessment lacked new evidence and was solely a reevaluation of existing information considered during the original assessment. The court upheld these findings, dismissing the Revenue's appeal. en-us Tue, 02 Jun 2015 00:00:00 +0530 Wed, 04 May 2016 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260572 The court held that the reassessment proceedings under Section 147 of the Income Tax Act were invalid as they were based on a mere change of opinion without any fresh material. The reassessment notice issued beyond four years was deemed without jurisdiction. Both the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal concluded that the reassessment lacked new evidence and was solely a reevaluation of existing information considered during the original assessment. The court upheld these findings, dismissing the Revenue's appeal. Case-Laws Income Tax Tue, 02 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260572