https://www.taxtmi.com/caselaws?id=412128 The court allowed the writ appeal, setting aside the impugned order and quashing the reassessment proceedings initiated under Section 147 of the Income Tax Act. The court held that the reassessment was based on a mere change of opinion and lacked jurisdiction, rendering it invalid. The appellant successfully challenged the reassessment on grounds of non-disclosure of primary facts, absence of ratification certificate, and the impact of CBDT Instruction No.2/2009, ultimately leading to the invalidation of the reassessment proceedings. en-us Fri, 03 Sep 2021 00:00:00 +0530 Fri, 10 Sep 2021 09:07:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412128 The court allowed the writ appeal, setting aside the impugned order and quashing the reassessment proceedings initiated under Section 147 of the Income Tax Act. The court held that the reassessment was based on a mere change of opinion and lacked jurisdiction, rendering it invalid. The appellant successfully challenged the reassessment on grounds of non-disclosure of primary facts, absence of ratification certificate, and the impact of CBDT Instruction No.2/2009, ultimately leading to the invalidation of the reassessment proceedings. Case-Laws Income Tax Fri, 03 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412128