https://www.taxtmi.com/caselaws?id=427107 The tribunal dismissed the revenue's appeal and upheld the Ld. CIT(A)'s decision regarding the validity of the notice under section 148 of the Income Tax Act, 1961 for reassessment. The tribunal found that the reassessment was not valid as it was based on the same material available during the original assessment, constituting a 'change of opinion.' The tribunal emphasized that the power to reassess cannot be triggered solely by a change of opinion and that the reasons for reopening an assessment must align with the material available during the original assessment. en-us Tue, 30 Aug 2022 00:00:00 +0530 Thu, 01 Sep 2022 10:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427107 The tribunal dismissed the revenue's appeal and upheld the Ld. CIT(A)'s decision regarding the validity of the notice under section 148 of the Income Tax Act, 1961 for reassessment. The tribunal found that the reassessment was not valid as it was based on the same material available during the original assessment, constituting a 'change of opinion.' The tribunal emphasized that the power to reassess cannot be triggered solely by a change of opinion and that the reasons for reopening an assessment must align with the material available during the original assessment. Case-Laws Income Tax Tue, 30 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427107