https://www.taxtmi.com/caselaws?id=435859 The court quashed the impugned notice dated 21st March 2021 and the order dated 22nd November 2021, finding the reopening of assessment impermissible as it was based on a change of opinion without fresh tangible material. The reopening beyond four years was deemed unsustainable since there was no failure by the assessee to disclose material facts. The court allowed the special civil application and made the rule absolute, with no order as to costs. en-us Mon, 20 Mar 2023 00:00:00 +0530 Wed, 13 Dec 2023 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435859 The court quashed the impugned notice dated 21st March 2021 and the order dated 22nd November 2021, finding the reopening of assessment impermissible as it was based on a change of opinion without fresh tangible material. The reopening beyond four years was deemed unsustainable since there was no failure by the assessee to disclose material facts. The court allowed the special civil application and made the rule absolute, with no order as to costs. Case-Laws Income Tax Mon, 20 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435859