https://www.taxtmi.com/caselaws?id=336642 The court upheld the ITAT's dismissal of the revenue's appeal, emphasizing that the facts were adequately considered. The re-assessment under Section 143(3) read with Section 147 was deemed invalid as it constituted a change of opinion without new material. The court found the notice under Section 148 to be invalid, lacking tangible material. Explanation 3 to Section 147 was not applicable due to the invalid notice. Consequently, the re-assessment proceedings were declared invalid, and the appeal was dismissed against the appellant. en-us Wed, 14 Dec 2016 00:00:00 +0530 Mon, 26 Dec 2016 14:18:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336642 The court upheld the ITAT's dismissal of the revenue's appeal, emphasizing that the facts were adequately considered. The re-assessment under Section 143(3) read with Section 147 was deemed invalid as it constituted a change of opinion without new material. The court found the notice under Section 148 to be invalid, lacking tangible material. Explanation 3 to Section 147 was not applicable due to the invalid notice. Consequently, the re-assessment proceedings were declared invalid, and the appeal was dismissed against the appellant. Case-Laws Income Tax Wed, 14 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336642