https://www.taxtmi.com/caselaws?id=410200 The court dismissed the appeal, upholding the decision that the reassessment proceedings under Section 147 were not maintainable due to the absence of failure to disclose material facts by the respondent and being a case of "change of opinion." The court rejected the argument regarding the extension of the four-year period under the third proviso to Section 147. The appeal was dismissed, and the order was directed to be uploaded on the website and forwarded to the learned counsel through e-mail. en-us Mon, 19 Jul 2021 00:00:00 +0530 Fri, 22 Oct 2021 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=410200 The court dismissed the appeal, upholding the decision that the reassessment proceedings under Section 147 were not maintainable due to the absence of failure to disclose material facts by the respondent and being a case of "change of opinion." The court rejected the argument regarding the extension of the four-year period under the third proviso to Section 147. The appeal was dismissed, and the order was directed to be uploaded on the website and forwarded to the learned counsel through e-mail. Case-Laws Income Tax Mon, 19 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=410200