https://www.taxtmi.com/caselaws?id=460073 The court quashed the reassessment proceedings, ruling that the Assessing Officer (AO) lacked jurisdiction as the reopening was not based on an independent belief but solely on information from the Investigation Wing. The court found no new material facts or failure to disclose by the assessee, deeming the reassessment invalid under Sections 147 and 148 of the Income Tax Act. It emphasized that a mere change of opinion cannot justify reopening a completed assessment. Consequently, the revenue's appeal was rendered infructuous. en-us Thu, 30 Sep 2010 00:00:00 +0530 Fri, 10 Jan 2025 12:10:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460073 The court quashed the reassessment proceedings, ruling that the Assessing Officer (AO) lacked jurisdiction as the reopening was not based on an independent belief but solely on information from the Investigation Wing. The court found no new material facts or failure to disclose by the assessee, deeming the reassessment invalid under Sections 147 and 148 of the Income Tax Act. It emphasized that a mere change of opinion cannot justify reopening a completed assessment. Consequently, the revenue's appeal was rendered infructuous. Case-Laws Income Tax Thu, 30 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460073