https://www.taxtmi.com/caselaws?id=416326 The High Court found discrepancies in the reasons for initiating proceedings under Section 148 of the Income Tax Act, determining it as a change of opinion impermissible under Section 147. The Court emphasized that the power under Section 147 cannot be used to review an assessment order based on the same facts. The re-opening of assessment was deemed a change of opinion without new material, leading to the petition being disposed of in favor of the petitioner, quashing the notice to re-open assessment and the order rejecting objections. en-us Tue, 21 Dec 2021 00:00:00 +0530 Sat, 01 Aug 2026 10:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416326 The High Court found discrepancies in the reasons for initiating proceedings under Section 148 of the Income Tax Act, determining it as a change of opinion impermissible under Section 147. The Court emphasized that the power under Section 147 cannot be used to review an assessment order based on the same facts. The re-opening of assessment was deemed a change of opinion without new material, leading to the petition being disposed of in favor of the petitioner, quashing the notice to re-open assessment and the order rejecting objections. Case-Laws Income Tax Tue, 21 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416326