https://www.taxtmi.com/caselaws?id=34561 The court upheld the validity of reopening assessments under Section 147/148 of the Income Tax Act for Assessment Years 1977-1978 to 1982-1983. It found sufficient material justifying the reopening, dismissing claims of a mere change of opinion. The court emphasized the requirement of "reasons to believe" income escaped assessment and applied the doctrine of incorporation to sustain the notices under Section 147(a) without relying on Section 147(b). The writ petitions were dismissed, and parties were directed to bear their own costs. en-us Wed, 09 Sep 2009 00:00:00 +0530 Thu, 15 Mar 2012 16:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=34561 The court upheld the validity of reopening assessments under Section 147/148 of the Income Tax Act for Assessment Years 1977-1978 to 1982-1983. It found sufficient material justifying the reopening, dismissing claims of a mere change of opinion. The court emphasized the requirement of "reasons to believe" income escaped assessment and applied the doctrine of incorporation to sustain the notices under Section 147(a) without relying on Section 147(b). The writ petitions were dismissed, and parties were directed to bear their own costs. Case-Laws Income Tax Wed, 09 Sep 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34561