https://www.taxtmi.com/caselaws?id=61539 The Tribunal invalidated the reopening of assessments for the years 1995-96, 1996-97, and 1997-98, citing the absence of any failure by the assessee to disclose material facts. It ruled that reopening based on a mere change of opinion is impermissible under Section 147. Consequently, reassessment notices under Section 148 were deemed invalid, and the reassessments were canceled. The Tribunal also found the rejection of the accounting method and the application of a net profit rate unjustified, leading to the annulment of additions made by the AO and CIT(A). The assessee's appeals were allowed, and the Revenue's appeals were dismissed as infructuous. en-us Mon, 14 Mar 2005 00:00:00 +0530 Fri, 24 May 2024 14:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61539 The Tribunal invalidated the reopening of assessments for the years 1995-96, 1996-97, and 1997-98, citing the absence of any failure by the assessee to disclose material facts. It ruled that reopening based on a mere change of opinion is impermissible under Section 147. Consequently, reassessment notices under Section 148 were deemed invalid, and the reassessments were canceled. The Tribunal also found the rejection of the accounting method and the application of a net profit rate unjustified, leading to the annulment of additions made by the AO and CIT(A). The assessee's appeals were allowed, and the Revenue's appeals were dismissed as infructuous. Case-Laws Income Tax Mon, 14 Mar 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61539