https://www.taxtmi.com/caselaws?id=415552 The Court held that the notice issued under Section 148 of the Income Tax Act, 1961 was without jurisdiction as it failed to specify the material facts not fully disclosed by the petitioner, as required by the proviso to Section 147. The Court found that the reasons for reopening the assessment indicated a change of opinion rather than a valid reason for reassessment, rendering the notice invalid. Consequently, the petition was allowed, and a writ was issued to quash the notices and orders, with no costs imposed. en-us Sat, 04 Dec 2021 00:00:00 +0530 Thu, 28 Apr 2022 18:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415552 The Court held that the notice issued under Section 148 of the Income Tax Act, 1961 was without jurisdiction as it failed to specify the material facts not fully disclosed by the petitioner, as required by the proviso to Section 147. The Court found that the reasons for reopening the assessment indicated a change of opinion rather than a valid reason for reassessment, rendering the notice invalid. Consequently, the petition was allowed, and a writ was issued to quash the notices and orders, with no costs imposed. Case-Laws Income Tax Sat, 04 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415552