https://www.taxtmi.com/caselaws?id=36270 The court held that the notice issued under Section 148 of the Income Tax Act, 1961, seeking to reopen the assessment was invalid as it was based on a change of opinion rather than new information. The court found that the audit objections and reasons provided did not constitute new facts but were merely opinions on the adequacy of the original assessment. Consequently, the court deemed the notice ultra vires and null and void, granting the petitioner a writ of mandamus to quash the notice and restraining the respondent from further proceedings. en-us Thu, 28 Feb 1980 00:00:00 +0530 Sat, 20 Mar 2010 13:27:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36270 The court held that the notice issued under Section 148 of the Income Tax Act, 1961, seeking to reopen the assessment was invalid as it was based on a change of opinion rather than new information. The court found that the audit objections and reasons provided did not constitute new facts but were merely opinions on the adequacy of the original assessment. Consequently, the court deemed the notice ultra vires and null and void, granting the petitioner a writ of mandamus to quash the notice and restraining the respondent from further proceedings. Case-Laws Income Tax Thu, 28 Feb 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36270