https://www.taxtmi.com/caselaws?id=35262 The court upheld the department's right to re-open the assessment under Section 148 of the Income Tax Act, 1961, due to an error on the face of the record. The challenge to the notice was dismissed, with the court directing the petitioner to pursue remedies within the department and clarifying that their observations should not be seen as an opinion on the case's substance. The judgment emphasized that the department's actions did not constitute a change of opinion and did not fall under the prohibition for re-opening assessment proceedings due to income escapement. en-us Wed, 11 Nov 2009 00:00:00 +0530 Tue, 09 Feb 2010 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35262 The court upheld the department's right to re-open the assessment under Section 148 of the Income Tax Act, 1961, due to an error on the face of the record. The challenge to the notice was dismissed, with the court directing the petitioner to pursue remedies within the department and clarifying that their observations should not be seen as an opinion on the case's substance. The judgment emphasized that the department's actions did not constitute a change of opinion and did not fall under the prohibition for re-opening assessment proceedings due to income escapement. Case-Laws Income Tax Wed, 11 Nov 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35262