https://www.taxtmi.com/caselaws?id=420970 The Bombay High Court held that the assessment cannot be reopened solely on a change of opinion and emphasized the importance of the assessee disclosing all primary facts relevant to assessment. In this case, as the petitioner had disclosed all material facts during the original assessment, the court quashed the notice under Section 148, highlighting that there was no failure on the part of the assessee to disclose material facts. The judgment underscored that reopening assessments based on a mere change of opinion is impermissible under the law. en-us Wed, 06 Apr 2022 00:00:00 +0530 Thu, 14 Apr 2022 08:09:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420970 The Bombay High Court held that the assessment cannot be reopened solely on a change of opinion and emphasized the importance of the assessee disclosing all primary facts relevant to assessment. In this case, as the petitioner had disclosed all material facts during the original assessment, the court quashed the notice under Section 148, highlighting that there was no failure on the part of the assessee to disclose material facts. The judgment underscored that reopening assessments based on a mere change of opinion is impermissible under the law. Case-Laws Income Tax Wed, 06 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420970