https://www.taxtmi.com/caselaws?id=328580 The court held that the notice issued under Section 148 of the Income Tax Act for reopening the assessment was invalid as it constituted a change of opinion without any new material. The court quashed the notice, ruling it was beyond the permissible period and lacked jurisdiction. It was emphasized that the petitioner had fully disclosed all necessary facts during the initial assessment, and the reassessment was based on the same facts, indicating a change of opinion rather than new material. en-us Mon, 28 Mar 2016 00:00:00 +0530 Thu, 17 Nov 2016 18:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328580 The court held that the notice issued under Section 148 of the Income Tax Act for reopening the assessment was invalid as it constituted a change of opinion without any new material. The court quashed the notice, ruling it was beyond the permissible period and lacked jurisdiction. It was emphasized that the petitioner had fully disclosed all necessary facts during the initial assessment, and the reassessment was based on the same facts, indicating a change of opinion rather than new material. Case-Laws Income Tax Mon, 28 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328580