https://www.taxtmi.com/caselaws?id=285574 The appeal was filed by the revenue against the order of the Learned Commissioner of Income Tax (Appeals)-4, Kolkata, regarding Assessment Year 2006-07. The primary issue was the validity of the notice issued under Section 148 of the Income Tax Act. The reassessment was sought based on a change in opinion on the same set of facts, which was held to be impermissible. The reassessment was done on an audit query, not due to a failure on the part of the assessee to disclose all material facts. Therefore, the reassessment was held to be barred by limitation and was quashed. The appeal of the revenue was dismissed. en-us Fri, 09 Nov 2018 00:00:00 +0530 Sat, 18 Jan 2020 10:07:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285574 The appeal was filed by the revenue against the order of the Learned Commissioner of Income Tax (Appeals)-4, Kolkata, regarding Assessment Year 2006-07. The primary issue was the validity of the notice issued under Section 148 of the Income Tax Act. The reassessment was sought based on a change in opinion on the same set of facts, which was held to be impermissible. The reassessment was done on an audit query, not due to a failure on the part of the assessee to disclose all material facts. Therefore, the reassessment was held to be barred by limitation and was quashed. The appeal of the revenue was dismissed. Case-Laws Income Tax Fri, 09 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285574