https://www.taxtmi.com/caselaws?id=10837 The court held that the notice issued under Section 148 read with Section 147 of the Income-tax Act, 1961, for reopening the assessment was invalid as the condition precedent for invoking powers under Section 147 was not fulfilled. The court also ruled that the retrospective amendment introduced by Explanation 8 to Section 43(1) did not apply to the assessee as they filed their return before the legislative change. Additionally, the court found no failure on the part of the assessee to disclose material facts necessary for assessment. Consequently, the court allowed the petition, quashing the notice and making no order as to costs. en-us Thu, 15 Jul 2004 00:00:00 +0530 Sat, 25 Jul 2009 17:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10837 The court held that the notice issued under Section 148 read with Section 147 of the Income-tax Act, 1961, for reopening the assessment was invalid as the condition precedent for invoking powers under Section 147 was not fulfilled. The court also ruled that the retrospective amendment introduced by Explanation 8 to Section 43(1) did not apply to the assessee as they filed their return before the legislative change. Additionally, the court found no failure on the part of the assessee to disclose material facts necessary for assessment. Consequently, the court allowed the petition, quashing the notice and making no order as to costs. Case-Laws Income Tax Thu, 15 Jul 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10837