https://www.taxtmi.com/caselaws?id=410665 The court upheld the legality of the reopening proceedings under Section 147 of the Income Tax Act, emphasizing the need for tangible materials supporting the decision. It found the reasons for reopening, though delayed, were recorded before issuing the notice, complying with procedural requirements. The distinction between "reason to believe" and "change of opinion" was clarified, with the court determining that new details justified the reopening. The court advised the petitioner to engage in the reassessment process, dismissing the writ petitions and allowing the reopening proceedings to proceed promptly. en-us Tue, 13 Jul 2021 00:00:00 +0530 Fri, 24 Dec 2021 12:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=410665 The court upheld the legality of the reopening proceedings under Section 147 of the Income Tax Act, emphasizing the need for tangible materials supporting the decision. It found the reasons for reopening, though delayed, were recorded before issuing the notice, complying with procedural requirements. The distinction between "reason to believe" and "change of opinion" was clarified, with the court determining that new details justified the reopening. The court advised the petitioner to engage in the reassessment process, dismissing the writ petitions and allowing the reopening proceedings to proceed promptly. Case-Laws Income Tax Tue, 13 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=410665