https://www.taxtmi.com/caselaws?id=434457 The court quashed the notice under Section 148 of the Income Tax Act, 1961, for reopening the assessment, as it was issued without specifying undisclosed information and was based on a change of opinion. The court found that the jurisdictional requirements for reassessment beyond four years were not met, as there was no failure to disclose material facts by the Petitioner. The reassessment lacked new tangible material and was deemed impermissible. Consequently, the court allowed the Petition, setting aside all related proceedings. en-us Thu, 09 Feb 2023 00:00:00 +0530 Fri, 24 Feb 2023 09:07:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434457 The court quashed the notice under Section 148 of the Income Tax Act, 1961, for reopening the assessment, as it was issued without specifying undisclosed information and was based on a change of opinion. The court found that the jurisdictional requirements for reassessment beyond four years were not met, as there was no failure to disclose material facts by the Petitioner. The reassessment lacked new tangible material and was deemed impermissible. Consequently, the court allowed the Petition, setting aside all related proceedings. Case-Laws Income Tax Thu, 09 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434457