https://www.taxtmi.com/caselaws?id=19206 The court held that the notice issued under section 147 of the Income-tax Act, 1961 for the assessment year 1984-85 was invalid as it was based on a mere change of opinion, not a valid ground for reopening assessment. The court found that the original assessment had thoroughly examined the matter, with the syndicate's existence and profit sharing already accepted by appellate authorities. As the reopening was deemed without jurisdiction, the court quashed the notice, ruling in favor of the petitioner and making the writ petition absolute. en-us Mon, 02 Jan 1995 00:00:00 +0530 Wed, 04 Nov 2009 16:18:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19206 The court held that the notice issued under section 147 of the Income-tax Act, 1961 for the assessment year 1984-85 was invalid as it was based on a mere change of opinion, not a valid ground for reopening assessment. The court found that the original assessment had thoroughly examined the matter, with the syndicate's existence and profit sharing already accepted by appellate authorities. As the reopening was deemed without jurisdiction, the court quashed the notice, ruling in favor of the petitioner and making the writ petition absolute. Case-Laws Income Tax Mon, 02 Jan 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19206