https://www.taxtmi.com/caselaws?id=17060 The Court affirmed the Tribunal's decision, declaring the reassessments made under section 147(b) invalid for the assessment years in question. The judgment emphasized the importance of distinguishing between factual and legal implications in audit reports and upheld the Tribunal's authority as the highest fact-finding body. The Department's argument that the reassessments were based on an internal audit report and not a change of opinion was rejected, leading to the reassessments being deemed invalid. en-us Thu, 08 Aug 1996 00:00:00 +0530 Tue, 15 Sep 2009 10:08:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17060 The Court affirmed the Tribunal's decision, declaring the reassessments made under section 147(b) invalid for the assessment years in question. The judgment emphasized the importance of distinguishing between factual and legal implications in audit reports and upheld the Tribunal's authority as the highest fact-finding body. The Department's argument that the reassessments were based on an internal audit report and not a change of opinion was rejected, leading to the reassessments being deemed invalid. Case-Laws Income Tax Thu, 08 Aug 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17060