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2002 (8) TMI 53 - HC - Income TaxBy this writ petition, the assessee-petitioner has challenged initiation of reassessment proceedings against it for the assessment years 1981-82, 1982-83, 1983-84, 1984-85 and 1985-86 by issuing notices under section 147/148 of the Income-tax Act, 1961, on March 29, 1990, on multiple grounds including that the notices are barred by time and that there exists no material on the basis of which a satisfaction about escapement of income for the relevant assessment years from tax could be reached. - in my opinion, merely a change of opinion, is not permissible for assuming jurisdiction under section 147 of the Act. Moreover, in the facts and circumstances of this case, as noticed above, when the principle regarding computation of depreciation on the acquisition valuation of the asset, i.e., Umaid Bhawan Palace, by the petitioner-company has become final for the periods prior to the period in question, and for the periods subsequent to the period in question, no useful purpose will be served in permitting the Assessing Officer to continue the reassessment proceedings now. - Accordingly, this writ petition is allowed and the notices for reopening the assessment are set aside and quashed.
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