https://www.taxtmi.com/caselaws?id=14009 HC set aside the reopening notice issued after four years, holding that reassessment was based on a condemned change of opinion rather than any failure by the assessee to disclose material facts. The court found the prerequisites of the proviso to section 147 were not satisfied and Explanation 2 was inapplicable, as the reasons did not demonstrate nondisclosure. Section 149 merely fixes the time for service of notice; the notice under section 148 was therefore invalid for lack of the necessary precondition and was quashed. en-us Mon, 02 Jul 2001 00:00:00 +0530 Fri, 03 Oct 2025 20:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14009 HC set aside the reopening notice issued after four years, holding that reassessment was based on a condemned change of opinion rather than any failure by the assessee to disclose material facts. The court found the prerequisites of the proviso to section 147 were not satisfied and Explanation 2 was inapplicable, as the reasons did not demonstrate nondisclosure. Section 149 merely fixes the time for service of notice; the notice under section 148 was therefore invalid for lack of the necessary precondition and was quashed. Case-Laws Income Tax Mon, 02 Jul 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14009