https://www.taxtmi.com/caselaws?id=438156 The HC held the re-assessment proceedings under Section 148 of the Income Tax Act, 1961, invalid due to a change of opinion and improper authority granting satisfaction. The re-assessment was based on a previously accepted deduction, constituting a change of opinion, which is not permissible for reopening assessments. Additionally, the satisfaction was obtained from an authority not covered under Section 151(1). Thus, the notice dated 01.01.2019 and the letter dated 20.05.2019 were quashed. The writ petition was allowed, merging the interim order with the final order. No costs were awarded. en-us Wed, 17 May 2023 00:00:00 +0530 Thu, 11 Jan 2024 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438156 The HC held the re-assessment proceedings under Section 148 of the Income Tax Act, 1961, invalid due to a change of opinion and improper authority granting satisfaction. The re-assessment was based on a previously accepted deduction, constituting a change of opinion, which is not permissible for reopening assessments. Additionally, the satisfaction was obtained from an authority not covered under Section 151(1). Thus, the notice dated 01.01.2019 and the letter dated 20.05.2019 were quashed. The writ petition was allowed, merging the interim order with the final order. No costs were awarded. Case-Laws Income Tax Wed, 17 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438156