https://www.taxtmi.com/caselaws?id=419935 The High Court quashed the notice issued under Section 148 of the Income Tax Act for A.Y. 2015-2016 as it was solely based on a change of opinion by the Assessing Officer, which is impermissible after the 4-year limit unless there was a failure to disclose material facts by the assessee. The court emphasized that reopening assessments based on the same material to reach a different view is not allowed, especially when all necessary facts were disclosed during the original assessment proceedings. The court criticized the Faceless Assessing Officer for not justifying the notice issuance and ruled in favor of the petitioner, setting aside the notice and related orders. en-us Wed, 09 Mar 2022 00:00:00 +0530 Wed, 23 Mar 2022 08:40:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=419935 The High Court quashed the notice issued under Section 148 of the Income Tax Act for A.Y. 2015-2016 as it was solely based on a change of opinion by the Assessing Officer, which is impermissible after the 4-year limit unless there was a failure to disclose material facts by the assessee. The court emphasized that reopening assessments based on the same material to reach a different view is not allowed, especially when all necessary facts were disclosed during the original assessment proceedings. The court criticized the Faceless Assessing Officer for not justifying the notice issuance and ruled in favor of the petitioner, setting aside the notice and related orders. Case-Laws Income Tax Wed, 09 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=419935