https://www.taxtmi.com/caselaws?id=387857 The Court held that the notice to reopen the assessment under Section 148 of the Income Tax Act for the Assessment Year 2012-13 lacked jurisdiction as it was based on a change of opinion and did not reveal any failure to disclose material facts during the original assessment. The Court emphasized that the reasons for reopening must be solely derived from the original recorded facts and not subsequent discoveries, setting aside the notice and allowing the petition. The jurisdiction to reopen an assessment is contingent upon meeting the jurisdictional prerequisites established by the reasons recorded at the notice's issuance. en-us Thu, 17 Oct 2019 00:00:00 +0530 Sat, 02 Nov 2019 21:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=387857 The Court held that the notice to reopen the assessment under Section 148 of the Income Tax Act for the Assessment Year 2012-13 lacked jurisdiction as it was based on a change of opinion and did not reveal any failure to disclose material facts during the original assessment. The Court emphasized that the reasons for reopening must be solely derived from the original recorded facts and not subsequent discoveries, setting aside the notice and allowing the petition. The jurisdiction to reopen an assessment is contingent upon meeting the jurisdictional prerequisites established by the reasons recorded at the notice's issuance. Case-Laws Income Tax Thu, 17 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=387857