https://www.taxtmi.com/caselaws?id=174873 The Tribunal upheld the CIT(A)'s decision to cancel the assessments for the mentioned years, ruling that the reassessment proceedings initiated by the A.O. were barred by limitation and without jurisdiction as they were based on the same material available during the original assessment, amounting to a change of opinion. The Tribunal found that there was no specific recording of failure to disclose material facts by the assessee, deeming the assessments made in 2007 as legally flawed. Consequently, the Revenue's appeal for both years was dismissed. en-us Fri, 18 Feb 2011 00:00:00 +0530 Mon, 26 Oct 2015 17:34:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=174873 The Tribunal upheld the CIT(A)'s decision to cancel the assessments for the mentioned years, ruling that the reassessment proceedings initiated by the A.O. were barred by limitation and without jurisdiction as they were based on the same material available during the original assessment, amounting to a change of opinion. The Tribunal found that there was no specific recording of failure to disclose material facts by the assessee, deeming the assessments made in 2007 as legally flawed. Consequently, the Revenue's appeal for both years was dismissed. Case-Laws Income Tax Fri, 18 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=174873