https://www.taxtmi.com/caselaws?id=418787 The court quashed the notice under Section 148 of the Income Tax Act and subsequent actions, ruling in favor of the petitioner. The court found that the notice lacked the necessary "reason to believe" for income escapement and failed to meet jurisdictional conditions for invoking Section 147. It emphasized the importance of full and true disclosure of material facts by the assessee and deemed the attempt to reopen the assessment as a mere change of opinion, legally impermissible. The petition was allowed, and no costs were awarded, underscoring the significance of adhering to jurisdictional conditions in reopening assessments. en-us Fri, 18 Feb 2022 00:00:00 +0530 Thu, 24 Feb 2022 07:13:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418787 The court quashed the notice under Section 148 of the Income Tax Act and subsequent actions, ruling in favor of the petitioner. The court found that the notice lacked the necessary "reason to believe" for income escapement and failed to meet jurisdictional conditions for invoking Section 147. It emphasized the importance of full and true disclosure of material facts by the assessee and deemed the attempt to reopen the assessment as a mere change of opinion, legally impermissible. The petition was allowed, and no costs were awarded, underscoring the significance of adhering to jurisdictional conditions in reopening assessments. Case-Laws Income Tax Fri, 18 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418787