https://www.taxtmi.com/caselaws?id=331947 The court allowed the writ petition challenging the reopening of assessment under Section 148 of the Income Tax Act, 1961 for the year 2008-2009. The court held that the notice lacked reasons for reopening and exceeded the statutory limit of 4 years without falling under failure to disclose facts. The Assessing Officer's attempt to tax profit on land sale for a Special Economic Zone, contrary to the initial claim of agricultural land, was deemed a change of opinion. The court emphasized the requirement of true and full disclosure to prevent arbitrary assessments, ultimately setting aside the reopening due to the thorough disclosure during the initial assessment. en-us Tue, 16 Aug 2016 00:00:00 +0530 Tue, 31 Jan 2017 18:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331947 The court allowed the writ petition challenging the reopening of assessment under Section 148 of the Income Tax Act, 1961 for the year 2008-2009. The court held that the notice lacked reasons for reopening and exceeded the statutory limit of 4 years without falling under failure to disclose facts. The Assessing Officer's attempt to tax profit on land sale for a Special Economic Zone, contrary to the initial claim of agricultural land, was deemed a change of opinion. The court emphasized the requirement of true and full disclosure to prevent arbitrary assessments, ultimately setting aside the reopening due to the thorough disclosure during the initial assessment. Case-Laws Income Tax Tue, 16 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331947