https://www.taxtmi.com/caselaws?id=301363 The court held that the respondent's jurisdiction to re-open the assessment under section 147 of the Income Tax Act, after four years from the relevant assessment year, was illegal and invalid. The court found that there was no failure on the petitioner's part to disclose material facts necessary for the assessment, and the re-opening was deemed a mere change of opinion without fresh tangible material. As a result, the proceedings initiated by the notice under section 148 of the Act were deemed unsustainable, leading to the allowance of the writ petition and closure of the connected miscellaneous petition. en-us Fri, 27 Apr 2012 00:00:00 +0530 Wed, 30 Mar 2022 16:29:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301363 The court held that the respondent's jurisdiction to re-open the assessment under section 147 of the Income Tax Act, after four years from the relevant assessment year, was illegal and invalid. The court found that there was no failure on the petitioner's part to disclose material facts necessary for the assessment, and the re-opening was deemed a mere change of opinion without fresh tangible material. As a result, the proceedings initiated by the notice under section 148 of the Act were deemed unsustainable, leading to the allowance of the writ petition and closure of the connected miscellaneous petition. Case-Laws Income Tax Fri, 27 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301363