https://www.taxtmi.com/caselaws?id=351042 The court found the reassessment based on a change of opinion impermissible under Section 147 of the Income Tax Act, as the primary facts were fully disclosed. The court also held that the Assessing Officer did not comply with the directives in GKN Drive Shafts (India) Limited, leading to flawed proceedings. Additionally, the court determined that the petitioners were unfairly singled out for reassessment, rendering the proceedings discriminatory. Consequently, the court quashed the illegal and unsustainable reopening notices and assessment orders, deeming them a clear case of change of opinion. en-us Mon, 13 Nov 2017 00:00:00 +0530 Mon, 14 May 2018 13:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=351042 The court found the reassessment based on a change of opinion impermissible under Section 147 of the Income Tax Act, as the primary facts were fully disclosed. The court also held that the Assessing Officer did not comply with the directives in GKN Drive Shafts (India) Limited, leading to flawed proceedings. Additionally, the court determined that the petitioners were unfairly singled out for reassessment, rendering the proceedings discriminatory. Consequently, the court quashed the illegal and unsustainable reopening notices and assessment orders, deeming them a clear case of change of opinion. Case-Laws Income Tax Mon, 13 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=351042