https://www.taxtmi.com/caselaws?id=59628 The Tribunal allowed the appeal, finding that the notice issued under section 148 was beyond the limitation period and based on a pure change of opinion. It held that the failure to challenge the notice before the AO or CIT(A) did not bar raising the issue before the Tribunal. The Tribunal emphasized that for the AO to assume jurisdiction beyond four years, there must be a failure to fully disclose all necessary facts, directing the CIT(A) to further adjudicate on the issue of failure to disclose material facts. The appeal was allowed for statistical purposes, with other grounds to be reconsidered after deciding the legal issue. en-us Mon, 30 Jan 2006 00:00:00 +0530 Fri, 31 Dec 2010 12:10:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59628 The Tribunal allowed the appeal, finding that the notice issued under section 148 was beyond the limitation period and based on a pure change of opinion. It held that the failure to challenge the notice before the AO or CIT(A) did not bar raising the issue before the Tribunal. The Tribunal emphasized that for the AO to assume jurisdiction beyond four years, there must be a failure to fully disclose all necessary facts, directing the CIT(A) to further adjudicate on the issue of failure to disclose material facts. The appeal was allowed for statistical purposes, with other grounds to be reconsidered after deciding the legal issue. Case-Laws Income Tax Mon, 30 Jan 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59628