https://www.taxtmi.com/caselaws?id=439566 The court quashed the impugned order and notice, ruling in favor of the petitioner. It held that the reopening of the assessment was not justified as it was based on a mere change of opinion without new tangible material. The court emphasized that reopening the assessment on the same grounds already scrutinized amounted to a change of opinion, citing relevant case law. Additionally, the court clarified that observations made were specific to Section 148 proceedings and not indicative of a stance on pending Section 263 proceedings. en-us Fri, 23 Jun 2023 00:00:00 +0530 Mon, 25 Sep 2023 10:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439566 The court quashed the impugned order and notice, ruling in favor of the petitioner. It held that the reopening of the assessment was not justified as it was based on a mere change of opinion without new tangible material. The court emphasized that reopening the assessment on the same grounds already scrutinized amounted to a change of opinion, citing relevant case law. Additionally, the court clarified that observations made were specific to Section 148 proceedings and not indicative of a stance on pending Section 263 proceedings. Case-Laws Income Tax Fri, 23 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439566