https://www.taxtmi.com/caselaws?id=16650 HC held that notices under s.148 for assessment years 1991-92, 1992-93 and 1993-94 were without jurisdiction and quashed. Although the revenue contended that manufacture of colour film rolls did not qualify for deduction under s.80-I, the Assessing Officer relied solely on a reconsideration of the same facts and orders already on record, with no new material, information or change of law between the assessments and formation of belief under s.147. The Court found this to be a mere change of opinion, which cannot sustain reopening under s.147/148, and struck down the impugned notices. en-us Thu, 28 May 1998 00:00:00 +0530 Fri, 10 Oct 2025 14:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16650 HC held that notices under s.148 for assessment years 1991-92, 1992-93 and 1993-94 were without jurisdiction and quashed. Although the revenue contended that manufacture of colour film rolls did not qualify for deduction under s.80-I, the Assessing Officer relied solely on a reconsideration of the same facts and orders already on record, with no new material, information or change of law between the assessments and formation of belief under s.147. The Court found this to be a mere change of opinion, which cannot sustain reopening under s.147/148, and struck down the impugned notices. Case-Laws Income Tax Thu, 28 May 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16650