https://www.taxtmi.com/caselaws?id=391651 The Court held that the notice issued under Section 148 of the Income Tax Act for reopening the assessment beyond four years was not sustainable as it was based on a change of opinion, which is impermissible. The Court found that there was no failure on the part of the assessee to disclose all material facts necessary for assessment. Consequently, the Court quashed the notice, terminated all consequential proceedings, and made the rule absolute. en-us Mon, 27 Jan 2020 00:00:00 +0530 Fri, 18 Sep 2020 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=391651 The Court held that the notice issued under Section 148 of the Income Tax Act for reopening the assessment beyond four years was not sustainable as it was based on a change of opinion, which is impermissible. The Court found that there was no failure on the part of the assessee to disclose all material facts necessary for assessment. Consequently, the Court quashed the notice, terminated all consequential proceedings, and made the rule absolute. Case-Laws Income Tax Mon, 27 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=391651