https://www.taxtmi.com/caselaws?id=29398 The court ruled in favor of the petitioners, finding that the Income Tax Officer's decision to issue a notice under section 148 of the Income Tax Act was based on a mere change of opinion and not valid grounds for reopening the assessment. The court emphasized that the petitioners had disclosed all relevant information, and the ITO's impression of incorrect assessment was deemed a change of opinion. Citing relevant case law, the court held that exercising jurisdiction under section 148 due to an audit objection was impermissible. As a result, the court deemed the ITO's jurisdiction irregular and struck down the notice issued under section 148, ruling in favor of the petitioners. en-us Mon, 19 Oct 1981 00:00:00 +0530 Fri, 12 Mar 2010 15:43:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29398 The court ruled in favor of the petitioners, finding that the Income Tax Officer's decision to issue a notice under section 148 of the Income Tax Act was based on a mere change of opinion and not valid grounds for reopening the assessment. The court emphasized that the petitioners had disclosed all relevant information, and the ITO's impression of incorrect assessment was deemed a change of opinion. Citing relevant case law, the court held that exercising jurisdiction under section 148 due to an audit objection was impermissible. As a result, the court deemed the ITO's jurisdiction irregular and struck down the notice issued under section 148, ruling in favor of the petitioners. Case-Laws Income Tax Mon, 19 Oct 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29398