https://www.taxtmi.com/caselaws?id=418845 The court ruled in favor of the petitioner in a case involving the transfer of a business through a slump sale agreement. The court held that the assessing officer's reopening of assessment under Section 147 was impermissible as it was based on a change of opinion, which is not a valid reason for reopening. The petitioner had complied with mandatory obligations for disclosure and had disclosed all material facts necessary for assessment. As the reopening was time-barred and the respondents failed to show a failure to disclose material facts, the court quashed the notices and orders issued by the assessing officer. en-us Mon, 21 Feb 2022 00:00:00 +0530 Mon, 15 May 2023 11:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418845 The court ruled in favor of the petitioner in a case involving the transfer of a business through a slump sale agreement. The court held that the assessing officer's reopening of assessment under Section 147 was impermissible as it was based on a change of opinion, which is not a valid reason for reopening. The petitioner had complied with mandatory obligations for disclosure and had disclosed all material facts necessary for assessment. As the reopening was time-barred and the respondents failed to show a failure to disclose material facts, the court quashed the notices and orders issued by the assessing officer. Case-Laws Income Tax Mon, 21 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418845