https://www.taxtmi.com/caselaws?id=337439 The court held that the notices under Section 148 of the Income Tax Act for reopening the assessment for AY 2006-07 were invalid as they amounted to a change of opinion by the Assessing Officer, which is impermissible. It was found that the depreciation on goodwill had been consistently allowed in previous assessments and was no longer debatable, leading to the conclusion that no income chargeable to tax had escaped assessment. Consequently, the court quashed the impugned notices and reassessment proceedings, declaring them invalid in favor of the petitioner in the Special Civil Application. en-us Thu, 29 Dec 2016 00:00:00 +0530 Mon, 09 Jan 2017 08:27:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=337439 The court held that the notices under Section 148 of the Income Tax Act for reopening the assessment for AY 2006-07 were invalid as they amounted to a change of opinion by the Assessing Officer, which is impermissible. It was found that the depreciation on goodwill had been consistently allowed in previous assessments and was no longer debatable, leading to the conclusion that no income chargeable to tax had escaped assessment. Consequently, the court quashed the impugned notices and reassessment proceedings, declaring them invalid in favor of the petitioner in the Special Civil Application. Case-Laws Income Tax Thu, 29 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=337439