https://www.taxtmi.com/caselaws?id=418096 The court allowed the petition, quashing the notice, approval, and reassessment proceedings under sections 148 and 151 of the Income Tax Act, 1961. The court found that the reasons for reopening the assessment did not demonstrate a failure to disclose material facts but rather indicated a change of opinion, which is impermissible. Emphasizing established legal principles, the court held that errors discovered upon reconsideration of existing material do not justify reopening assessments. The court's decision was in favor of the petitioner, highlighting the restrictions on reopening assessments based on a change of opinion rather than a genuine failure to disclose material facts. en-us Thu, 03 Feb 2022 00:00:00 +0530 Tue, 08 Feb 2022 06:55:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418096 The court allowed the petition, quashing the notice, approval, and reassessment proceedings under sections 148 and 151 of the Income Tax Act, 1961. The court found that the reasons for reopening the assessment did not demonstrate a failure to disclose material facts but rather indicated a change of opinion, which is impermissible. Emphasizing established legal principles, the court held that errors discovered upon reconsideration of existing material do not justify reopening assessments. The court's decision was in favor of the petitioner, highlighting the restrictions on reopening assessments based on a change of opinion rather than a genuine failure to disclose material facts. Case-Laws Income Tax Thu, 03 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418096