https://www.taxtmi.com/caselaws?id=779437 HC held the reassessment invalid because the assessee had disclosed full and true primary facts in the return, so Section 147 could not be invoked. The court affirmed that mere change of opinion by the AO cannot justify reopening, following SC precedent. A second notice issued while an earlier notice subsisted was held invalid, rendering proceedings under that notice a nullity. In view of these defects, the writ petition was allowed and the reassessment proceedings were quashed. en-us Fri, 19 Sep 2025 00:00:00 +0530 Fri, 03 Oct 2025 12:29:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779437 HC held the reassessment invalid because the assessee had disclosed full and true primary facts in the return, so Section 147 could not be invoked. The court affirmed that mere change of opinion by the AO cannot justify reopening, following SC precedent. A second notice issued while an earlier notice subsisted was held invalid, rendering proceedings under that notice a nullity. In view of these defects, the writ petition was allowed and the reassessment proceedings were quashed. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779437