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Income Tax Officer, I Ward, Dist, Vi, ... vs Lakhmani Mewal Das on 30 March, 1976

7. Relying on the Supreme Court decision in ITO v. Lakhmani Mewal Das [1976] 103ITR 437, it was submitted that a mere change of opinion would not empower the Assessing Officer to reopen the assessment by issue of notice under Section 148. Reliance was also placed on the Punjab and Haryana High Court decision in the case of Mukhtiar Singh Sandhuv. ITO [1986] 160 ITR 526. It was submitted that the assessee could not be held guilty of not disclosing truly and correctly the material facts necessary for assessment and, therefore, the notices issued for reassessments were invalid.
Supreme Court of India Cites 15 - Cited by 885 - H R Khanna - Full Document

Shiv Lal Kanhaya Lal vs Commissioner Of Income-Tax on 19 September, 1985

8. Reliance was also placed on the Punjab and Haryana High Court decision in the case of Shiv Lal Kanhaya Lal v. CIT [1986] 162 ITR 548 for the proposition that reassessment proceedings on the basis of a mere change of opinion were invalid. It was vehemently argued that no new information had come into possession of the Assessing Officer which would clothe him with the powers to reopen the assessments particularly for assessment years 1985-86 and 1986-87.
Punjab-Haryana High Court Cites 5 - Cited by 3 - Full Document
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