https://www.taxtmi.com/caselaws?id=375372 The court issued a notice returnable on a specified date in response to the petitioner's arguments challenging the reopening of assessment under section 147 of the Income Tax Act, 1961. The petitioner raised concerns about the validity of the Assessing Officer's jurisdiction and the applicability of the proviso to section 147, emphasizing that the reopening seemed to be based on a change of opinion rather than new material facts. The respondent was allowed to proceed further with the notice, subject to the condition that the final order required court permission, and direct service of the notice was permitted for timely communication of the court's decision. en-us Thu, 20 Dec 2018 00:00:00 +0530 Mon, 18 Feb 2019 06:37:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375372 The court issued a notice returnable on a specified date in response to the petitioner's arguments challenging the reopening of assessment under section 147 of the Income Tax Act, 1961. The petitioner raised concerns about the validity of the Assessing Officer's jurisdiction and the applicability of the proviso to section 147, emphasizing that the reopening seemed to be based on a change of opinion rather than new material facts. The respondent was allowed to proceed further with the notice, subject to the condition that the final order required court permission, and direct service of the notice was permitted for timely communication of the court's decision. Case-Laws Income Tax Thu, 20 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375372