https://www.taxtmi.com/caselaws?id=418286 The High Court found the notice issued under section 148 of the Income Tax Act, 1961 for assessment year 2008-2009 to be invalid due to impermissible change of opinion by the Assessing Officer. The court noted discrepancies in the reasons for reopening the assessment and highlighted that relying on an ITAT order dated after the original assessment was completed was legally untenable. Citing precedent cases, the court quashed the notice and order, granting the Petition and issuing a writ of certiorari under Article 226 of the Constitution of India. en-us Thu, 10 Feb 2022 00:00:00 +0530 Fri, 11 Feb 2022 14:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418286 The High Court found the notice issued under section 148 of the Income Tax Act, 1961 for assessment year 2008-2009 to be invalid due to impermissible change of opinion by the Assessing Officer. The court noted discrepancies in the reasons for reopening the assessment and highlighted that relying on an ITAT order dated after the original assessment was completed was legally untenable. Citing precedent cases, the court quashed the notice and order, granting the Petition and issuing a writ of certiorari under Article 226 of the Constitution of India. Case-Laws Income Tax Thu, 10 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418286