https://www.taxtmi.com/caselaws?id=442273 The Tribunal quashed the assessment under Section 144 read with Section 147, ruling that the notice issued under Section 148 was invalid as it constituted a "mere change of opinion," following the precedent set in CIT, Delhi v. Kelvinator of India Ltd. The Tribunal found that the capital gains had been disclosed in the original assessment under Section 143(3), rendering the reassessment unnecessary. The disallowance of Rs. 32,18,238 under LTCG was not addressed due to the jurisdictional grounds leading to the assessment's annulment. en-us Thu, 24 Aug 2023 00:00:00 +0530 Sun, 27 Aug 2023 23:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442273 The Tribunal quashed the assessment under Section 144 read with Section 147, ruling that the notice issued under Section 148 was invalid as it constituted a "mere change of opinion," following the precedent set in CIT, Delhi v. Kelvinator of India Ltd. The Tribunal found that the capital gains had been disclosed in the original assessment under Section 143(3), rendering the reassessment unnecessary. The disallowance of Rs. 32,18,238 under LTCG was not addressed due to the jurisdictional grounds leading to the assessment's annulment. Case-Laws Income Tax Thu, 24 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442273