https://www.taxtmi.com/caselaws?id=424846 The court found that the initiation of the proceedings for reopening the assessment under Section 147 of the Income Tax Act, 1961, was not sustainable in law. The notice under Section 148 and all subsequent proceedings were quashed as they were based on the same material facts already considered during the original assessment. The court relied on precedent to determine that reopening the assessment on the same grounds without new material facts amounted to a change of opinion, which was not permissible. The writ petition was allowed, and no costs were awarded. en-us Tue, 05 Jul 2022 00:00:00 +0530 Fri, 09 Sep 2022 11:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=424846 The court found that the initiation of the proceedings for reopening the assessment under Section 147 of the Income Tax Act, 1961, was not sustainable in law. The notice under Section 148 and all subsequent proceedings were quashed as they were based on the same material facts already considered during the original assessment. The court relied on precedent to determine that reopening the assessment on the same grounds without new material facts amounted to a change of opinion, which was not permissible. The writ petition was allowed, and no costs were awarded. Case-Laws Income Tax Tue, 05 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=424846