https://www.taxtmi.com/caselaws?id=26032 The court held that the appellant had fully disclosed all necessary facts during the original assessment, and the Income-tax Officer's decision to reopen the assessment based on a change of opinion was not valid under Section 147 of the Income-tax Act, 1961. The court emphasized the importance of genuine and complete disclosure by the assessee and ruled in favor of the appellant. The appeal was allowed, the previous judgment and order were set aside, and the notice for reassessment was quashed. The court also rejected the Revenue's request for an appeal certificate, stating that no substantial legal question arose from the case. en-us Mon, 09 Dec 1985 00:00:00 +0530 Tue, 02 Feb 2010 13:27:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26032 The court held that the appellant had fully disclosed all necessary facts during the original assessment, and the Income-tax Officer's decision to reopen the assessment based on a change of opinion was not valid under Section 147 of the Income-tax Act, 1961. The court emphasized the importance of genuine and complete disclosure by the assessee and ruled in favor of the appellant. The appeal was allowed, the previous judgment and order were set aside, and the notice for reassessment was quashed. The court also rejected the Revenue's request for an appeal certificate, stating that no substantial legal question arose from the case. Case-Laws Income Tax Mon, 09 Dec 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26032