https://www.taxtmi.com/caselaws?id=27384 The court held that the notices issued by the Income Tax Officer (ITO) under section 148 for reopening completed assessments were invalid as the ITO failed to provide reasons or file an affidavit, as required by law. The court emphasized that a mere change of opinion is not a valid reason for invoking section 148, and the initiation of proceedings by the ITO was found to be without jurisdiction. Consequently, the court ruled in favor of the petitioner, quashing the notices and making the rule absolute without awarding costs. en-us Tue, 20 Dec 1983 00:00:00 +0530 Fri, 12 Feb 2010 14:05:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27384 The court held that the notices issued by the Income Tax Officer (ITO) under section 148 for reopening completed assessments were invalid as the ITO failed to provide reasons or file an affidavit, as required by law. The court emphasized that a mere change of opinion is not a valid reason for invoking section 148, and the initiation of proceedings by the ITO was found to be without jurisdiction. Consequently, the court ruled in favor of the petitioner, quashing the notices and making the rule absolute without awarding costs. Case-Laws Income Tax Tue, 20 Dec 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27384