https://www.taxtmi.com/caselaws?id=415884 The court found that the reasons provided for re-opening the assessment under Section 147 of the Income Tax Act 1961 were based on a change of opinion rather than undisclosed material facts. The court held that there was no failure to disclose material facts necessary for assessment, as the issues raised had been previously disclosed. Consequently, the re-opening was deemed invalid. The petition was allowed, and writs of certiorari were issued to quash the notice under Section 148 and the order rejecting objections. Another writ was issued to quash the order under Section 147, with no order as to cost. en-us Tue, 30 Nov 2021 00:00:00 +0530 Thu, 16 Dec 2021 09:08:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415884 The court found that the reasons provided for re-opening the assessment under Section 147 of the Income Tax Act 1961 were based on a change of opinion rather than undisclosed material facts. The court held that there was no failure to disclose material facts necessary for assessment, as the issues raised had been previously disclosed. Consequently, the re-opening was deemed invalid. The petition was allowed, and writs of certiorari were issued to quash the notice under Section 148 and the order rejecting objections. Another writ was issued to quash the order under Section 147, with no order as to cost. Case-Laws Income Tax Tue, 30 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415884