https://www.taxtmi.com/caselaws?id=435098 The court determined that the reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961, were invalid as they were based on a change of opinion rather than new tangible material. The court found that the petitioner had disclosed all necessary material facts during the original assessment, and the transfer pricing provisions were not applicable. The approval obtained under Section 151 was deemed invalid. Consequently, the court set aside the notice dated 11th March 2021 and the order dated 25th January 2022, halting all related proceedings. The petitions were disposed of without any order as to costs. en-us Wed, 08 Mar 2023 00:00:00 +0530 Mon, 27 Nov 2023 11:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435098 The court determined that the reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961, were invalid as they were based on a change of opinion rather than new tangible material. The court found that the petitioner had disclosed all necessary material facts during the original assessment, and the transfer pricing provisions were not applicable. The approval obtained under Section 151 was deemed invalid. Consequently, the court set aside the notice dated 11th March 2021 and the order dated 25th January 2022, halting all related proceedings. The petitions were disposed of without any order as to costs. Case-Laws Income Tax Wed, 08 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435098