2023 (1) TMI 73

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..... or reopening of the assessment beyond four years are not satisfied. The re-assessment was on change of opinion. There are no allegations of suppression of material fact. Under the circumstances, no error has been committed by the High Court in setting aside the re-opening notice under Section 148 - We are in complete agreement with the view taken by the High Court. The Special Leave Petition stand .....

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..... years are required to be satisfied . Having gone through the reasons recorded for re-opening, we are of the opinion that the conditions precedent for reopening of the assessment beyond four years are not satisfied. The re-assessment was on change of opinion. There are no allegations of suppression of material fact. Under the circumstances, no error has been committed by the High Court in setti .....

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