https://www.taxtmi.com/caselaws?id=8808 Reopening of assessment under section 147(a) was invalid where the original assessment had already examined the cash credits, accepted the assessee's explanation, and relied on the depositors' statements. A later enquiry by the income-tax inspector only led the successor officer to reassess the same material and reach a different view, which amounted to a mere change of opinion and did not establish failure to disclose fully and truly all primary facts. On that basis, the statutory condition for reopening was not met and the notice under section 148 was quashed; the question of satisfaction under section 151(2) was left undecided. en-us Thu, 22 Jun 1972 00:00:00 +0530 Thu, 04 Jun 2009 18:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8808 Reopening of assessment under section 147(a) was invalid where the original assessment had already examined the cash credits, accepted the assessee's explanation, and relied on the depositors' statements. A later enquiry by the income-tax inspector only led the successor officer to reassess the same material and reach a different view, which amounted to a mere change of opinion and did not establish failure to disclose fully and truly all primary facts. On that basis, the statutory condition for reopening was not met and the notice under section 148 was quashed; the question of satisfaction under section 151(2) was left undecided. Case-Laws Income Tax Thu, 22 Jun 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8808