https://www.taxtmi.com/caselaws?id=330252 The Court ruled in favor of the petitioner, finding the Notice under Section 148 of the Income Tax Act to reopen the assessment for A.Y. 1986-87 beyond the prescribed period and without disclosure of material facts to be without jurisdiction. The decision relied on legal precedents, including the case law Deputy Commissioner of Income Tax Vs. Simplex Concrete Piles (India) Ltd., emphasizing that a subsequent reversal of legal position does not warrant reopening assessments beyond four years without failure to disclose material facts. The judgment aligned with the petitioner, citing the retrospective effect of relevant amendments to the Act from 1989. en-us Thu, 14 Jul 2016 00:00:00 +0530 Tue, 19 Jul 2016 12:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330252 The Court ruled in favor of the petitioner, finding the Notice under Section 148 of the Income Tax Act to reopen the assessment for A.Y. 1986-87 beyond the prescribed period and without disclosure of material facts to be without jurisdiction. The decision relied on legal precedents, including the case law Deputy Commissioner of Income Tax Vs. Simplex Concrete Piles (India) Ltd., emphasizing that a subsequent reversal of legal position does not warrant reopening assessments beyond four years without failure to disclose material facts. The judgment aligned with the petitioner, citing the retrospective effect of relevant amendments to the Act from 1989. Case-Laws Income Tax Thu, 14 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330252