https://www.taxtmi.com/caselaws?id=437676 The court quashed the impugned notice dated 28.03.2021 and the impugned order dated 10.03.2021, allowing the petition. It held that the reopening of assessment under Section 148 of the Income Tax Act was impermissible as it was based on a mere change of opinion without fresh tangible material. The court found a fundamental error in the respondent's assumption of the land as open land rather than agricultural, as indicated by the sale document and stamp authority's valuation. The court emphasized that reopening based on a change of opinion is not permissible, referencing judicial precedents. en-us Wed, 03 May 2023 00:00:00 +0530 Thu, 14 Dec 2023 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437676 The court quashed the impugned notice dated 28.03.2021 and the impugned order dated 10.03.2021, allowing the petition. It held that the reopening of assessment under Section 148 of the Income Tax Act was impermissible as it was based on a mere change of opinion without fresh tangible material. The court found a fundamental error in the respondent's assumption of the land as open land rather than agricultural, as indicated by the sale document and stamp authority's valuation. The court emphasized that reopening based on a change of opinion is not permissible, referencing judicial precedents. Case-Laws Income Tax Wed, 03 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437676