https://www.taxtmi.com/caselaws?id=435033 The Court quashed the notice under section 148 of the Income Tax Act for reopening the assessment for AY 2008-09, citing a lack of fresh material and a mere change of opinion. The Petitioner's entitlement to carry forward and set off the deficit was upheld, emphasizing consistent application of principles from relevant cases. The Court found no failure to disclose material facts and deemed the reassessment notice a case of impermissible change of opinion. Consequently, the challenged notice and order were set aside, ruling in favor of the Petitioner without costs. en-us Wed, 08 Mar 2023 00:00:00 +0530 Fri, 10 Mar 2023 08:57:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435033 The Court quashed the notice under section 148 of the Income Tax Act for reopening the assessment for AY 2008-09, citing a lack of fresh material and a mere change of opinion. The Petitioner's entitlement to carry forward and set off the deficit was upheld, emphasizing consistent application of principles from relevant cases. The Court found no failure to disclose material facts and deemed the reassessment notice a case of impermissible change of opinion. Consequently, the challenged notice and order were set aside, ruling in favor of the Petitioner without costs. Case-Laws Income Tax Wed, 08 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435033