https://www.taxtmi.com/caselaws?id=432169 The court held that the notice issued under section 148 of the Income Tax Act for reopening the assessment was illegal as it amounted to a change of opinion by the Assessing Officer, which is impermissible. The court found that all material facts necessary for assessment were disclosed during the original assessment, and there was no failure on the part of the petitioner. Consequently, the court set aside the notice and the order disposing of objections against it, ruling in favor of the petitioner. en-us Fri, 16 Dec 2022 00:00:00 +0530 Wed, 28 Dec 2022 14:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432169 The court held that the notice issued under section 148 of the Income Tax Act for reopening the assessment was illegal as it amounted to a change of opinion by the Assessing Officer, which is impermissible. The court found that all material facts necessary for assessment were disclosed during the original assessment, and there was no failure on the part of the petitioner. Consequently, the court set aside the notice and the order disposing of objections against it, ruling in favor of the petitioner. Case-Laws Income Tax Fri, 16 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432169