https://www.taxtmi.com/caselaws?id=434204 The court held that the reopening of the assessment under Section 148 of the Income Tax Act, 1961, was invalid. It determined that the Assessing Officer (AO) failed to identify any specific material facts not disclosed by the petitioner, as the relevant details were already available in the audited accounts and financial statements. The court concluded that the reassessment proceedings constituted a mere change of opinion without any new tangible material. Consequently, the petition was allowed, and the notice under Section 148, along with the order rejecting the petitioner's objections, was set aside. en-us Wed, 15 Feb 2023 00:00:00 +0530 Mon, 27 Nov 2023 10:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434204 The court held that the reopening of the assessment under Section 148 of the Income Tax Act, 1961, was invalid. It determined that the Assessing Officer (AO) failed to identify any specific material facts not disclosed by the petitioner, as the relevant details were already available in the audited accounts and financial statements. The court concluded that the reassessment proceedings constituted a mere change of opinion without any new tangible material. Consequently, the petition was allowed, and the notice under Section 148, along with the order rejecting the petitioner's objections, was set aside. Case-Laws Income Tax Wed, 15 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434204