https://www.taxtmi.com/caselaws?id=38014 Reassessment under section 148 was invalid where the assessee had already disclosed the tenancy dispute, non-receipt of rent and other relevant property facts before the original assessment. On those facts, there was no failure to disclose fully and truly all material facts, so reopening could not be sustained under section 147(a). There was also no fresh external information or new material to support section 147(b); the notice rested only on a later officer's different appreciation of the same record, which amounted to a mere change of opinion. The reassessment notice was quashed. en-us Fri, 02 Jun 1978 00:00:00 +0530 Fri, 02 Apr 2010 15:30:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38014 Reassessment under section 148 was invalid where the assessee had already disclosed the tenancy dispute, non-receipt of rent and other relevant property facts before the original assessment. On those facts, there was no failure to disclose fully and truly all material facts, so reopening could not be sustained under section 147(a). There was also no fresh external information or new material to support section 147(b); the notice rested only on a later officer's different appreciation of the same record, which amounted to a mere change of opinion. The reassessment notice was quashed. Case-Laws Income Tax Fri, 02 Jun 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38014