https://www.taxtmi.com/caselaws?id=2971 The court ruled in favor of the petitioner, quashing the notice issued under section 148 of the Income Tax Act. It held that the assessing officer cannot reopen an assessment based solely on a change of opinion without new material. The court emphasized the need for new evidence indicating an error in the original assessment if the same issue is to be revisited. Additionally, it highlighted that relevant decisions, like one from the Kolkata Bench, should be considered, and unsupported rejection of such decisions is unjustified. The court found that the provision for deferred taxation did not lead to under-assessment during the original assessment, leading to the successful challenge of the reopening. en-us Wed, 17 Oct 2007 00:00:00 +0530 Wed, 30 Jul 2008 13:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=2971 The court ruled in favor of the petitioner, quashing the notice issued under section 148 of the Income Tax Act. It held that the assessing officer cannot reopen an assessment based solely on a change of opinion without new material. The court emphasized the need for new evidence indicating an error in the original assessment if the same issue is to be revisited. Additionally, it highlighted that relevant decisions, like one from the Kolkata Bench, should be considered, and unsupported rejection of such decisions is unjustified. The court found that the provision for deferred taxation did not lead to under-assessment during the original assessment, leading to the successful challenge of the reopening. Case-Laws Income Tax Wed, 17 Oct 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=2971