https://www.taxtmi.com/caselaws?id=416115 The High Court ruled in favor of the petitioner, emphasizing that the Assessing Officer did not meet the jurisdictional conditions required to initiate proceedings under Section 148 of the Income Tax Act. The court found that the reassessment was solely based on a change of opinion regarding the tax rate on capital gains, which had already been addressed during the initial assessment. It was concluded that the Assessing Officer had accepted the petitioner's explanations during the original assessment, indicating due application of mind. Therefore, the court quashed the notice and order, highlighting the importance of adhering to jurisdictional requirements before re-opening assessments. en-us Fri, 17 Dec 2021 00:00:00 +0530 Tue, 21 Dec 2021 08:45:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416115 The High Court ruled in favor of the petitioner, emphasizing that the Assessing Officer did not meet the jurisdictional conditions required to initiate proceedings under Section 148 of the Income Tax Act. The court found that the reassessment was solely based on a change of opinion regarding the tax rate on capital gains, which had already been addressed during the initial assessment. It was concluded that the Assessing Officer had accepted the petitioner's explanations during the original assessment, indicating due application of mind. Therefore, the court quashed the notice and order, highlighting the importance of adhering to jurisdictional requirements before re-opening assessments. Case-Laws Income Tax Fri, 17 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416115