https://www.taxtmi.com/caselaws?id=20502 The Tribunal held that there was no failure to disclose material facts by the assessee, and it was a case of a change of opinion rather than income escaping assessment. The court emphasized that the Income-tax Officer must have reasonable grounds to believe in non-disclosure of material facts for issuing a notice under section 147(a) of the Income-tax Act, 1961. The court found that the assessee had disclosed all relevant facts, and the subsequent change in opinion did not indicate income escaping assessment due to non-disclosure. The reassessment disallowing the claim for municipal taxes was set aside, ruling in favor of the assessee. en-us Mon, 22 Mar 1993 00:00:00 +0530 Sat, 14 Nov 2009 13:15:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20502 The Tribunal held that there was no failure to disclose material facts by the assessee, and it was a case of a change of opinion rather than income escaping assessment. The court emphasized that the Income-tax Officer must have reasonable grounds to believe in non-disclosure of material facts for issuing a notice under section 147(a) of the Income-tax Act, 1961. The court found that the assessee had disclosed all relevant facts, and the subsequent change in opinion did not indicate income escaping assessment due to non-disclosure. The reassessment disallowing the claim for municipal taxes was set aside, ruling in favor of the assessee. Case-Laws Income Tax Mon, 22 Mar 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20502