https://www.taxtmi.com/caselaws?id=28599 The court allowed the petition, quashed the notice issued under Section 148 of the Income Tax Act, and restrained further action. It held that the reassessment was not valid as it was based on a mere change of opinion without any failure to disclose material facts. The court found the reasons for reopening the assessment insufficient and emphasized that the petitioner had disclosed all primary facts during the original assessment. Additionally, it concluded that the CBDT's sanction for reopening the assessment was not mechanical. en-us Tue, 07 Sep 1982 00:00:00 +0530 Wed, 24 Feb 2010 10:19:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28599 The court allowed the petition, quashed the notice issued under Section 148 of the Income Tax Act, and restrained further action. It held that the reassessment was not valid as it was based on a mere change of opinion without any failure to disclose material facts. The court found the reasons for reopening the assessment insufficient and emphasized that the petitioner had disclosed all primary facts during the original assessment. Additionally, it concluded that the CBDT's sanction for reopening the assessment was not mechanical. Case-Laws Income Tax Tue, 07 Sep 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28599