https://www.taxtmi.com/caselaws?id=429168 The Tribunal held that the reopening of the assessment under section 147 of the Income Tax Act was invalid as it constituted a mere "change of opinion" without new tangible material, and there was no failure by the assessee to disclose all material facts. Consequently, the disallowance of the exemption under section 54F was also deemed invalid. The Tribunal allowed the appeal, setting aside the Commissioner of Income Tax (Appeals) order and quashing the assessment. en-us Wed, 12 Oct 2022 00:00:00 +0530 Wed, 19 Oct 2022 10:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429168 The Tribunal held that the reopening of the assessment under section 147 of the Income Tax Act was invalid as it constituted a mere "change of opinion" without new tangible material, and there was no failure by the assessee to disclose all material facts. Consequently, the disallowance of the exemption under section 54F was also deemed invalid. The Tribunal allowed the appeal, setting aside the Commissioner of Income Tax (Appeals) order and quashing the assessment. Case-Laws Income Tax Wed, 12 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429168