https://www.taxtmi.com/caselaws?id=434019 The HC determined that the notice issued under Section 148 of the IT Act was based on a change of opinion rather than any failure by the assessee to disclose material facts. The approval by the PCIT under Section 151 was also unjustified due to lack of new tangible material. Consequently, the court set aside the notice, rendering the writ petition absolute, with no order as to costs. en-us Fri, 10 Feb 2023 00:00:00 +0530 Wed, 27 Mar 2024 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434019 The HC determined that the notice issued under Section 148 of the IT Act was based on a change of opinion rather than any failure by the assessee to disclose material facts. The approval by the PCIT under Section 151 was also unjustified due to lack of new tangible material. Consequently, the court set aside the notice, rendering the writ petition absolute, with no order as to costs. Case-Laws Income Tax Fri, 10 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434019