https://www.taxtmi.com/caselaws?id=328173 The court ruled in favor of the Petitioners, finding the notices issued under Section 148 of the Income Tax Act for reopening assessments invalid due to a mere change of opinion by the Assessing Officer without fresh tangible material. The court also held that the non-compete fee from the sale of shares should not be taxed as business income, as the AO had already accepted the sale price without segregating the non-compete fee. Inconsistencies in treating similar transactions and a lack of substantial new evidence led to the court quashing the reassessment proceedings. en-us Mon, 16 May 2016 00:00:00 +0530 Wed, 10 Aug 2016 18:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328173 The court ruled in favor of the Petitioners, finding the notices issued under Section 148 of the Income Tax Act for reopening assessments invalid due to a mere change of opinion by the Assessing Officer without fresh tangible material. The court also held that the non-compete fee from the sale of shares should not be taxed as business income, as the AO had already accepted the sale price without segregating the non-compete fee. Inconsistencies in treating similar transactions and a lack of substantial new evidence led to the court quashing the reassessment proceedings. Case-Laws Income Tax Mon, 16 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328173