https://www.taxtmi.com/caselaws?id=12358 Reopening under ss. 147/148 was challenged on the ground that the statutory precondition of assessee's failure to disclose fully and truly all material facts was absent. The HC held that, at the original s. 143(3) assessments, the assessee had furnished prescribed CA certificates and all primary facts necessary for claiming exemption, and the recorded reasons did not allege any non-disclosure or specify any further primary facts required; reopening was therefore a mere change of opinion and beyond jurisdiction. Treating the initiation as palpably unwarranted and relying on Art. 226 to prevent futile reassessment proceedings, the HC quashed the s. 148 notices and all consequential proceedings, allowing the writ petition. en-us Thu, 12 Sep 2002 00:00:00 +0530 Wed, 24 Dec 2025 21:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12358 Reopening under ss. 147/148 was challenged on the ground that the statutory precondition of assessee's failure to disclose fully and truly all material facts was absent. The HC held that, at the original s. 143(3) assessments, the assessee had furnished prescribed CA certificates and all primary facts necessary for claiming exemption, and the recorded reasons did not allege any non-disclosure or specify any further primary facts required; reopening was therefore a mere change of opinion and beyond jurisdiction. Treating the initiation as palpably unwarranted and relying on Art. 226 to prevent futile reassessment proceedings, the HC quashed the s. 148 notices and all consequential proceedings, allowing the writ petition. Case-Laws Income Tax Thu, 12 Sep 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12358