Special leave petition dismissed; reopening assessment under Section 147 beyond four years held mere change of opinion, jurisdiction absent SC dismissed the special leave petition upholding the HC's finding that reopening assessment under s.147 by issuing notice beyond four years amounted to ...
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Special leave petition dismissed; reopening assessment under Section 147 beyond four years held mere change of opinion, jurisdiction absent
SC dismissed the special leave petition upholding the HC's finding that reopening assessment under s.147 by issuing notice beyond four years amounted to mere change of opinion. The Court agreed jurisdictional parameters for reopening were not met, noting no failure by the taxpayer to fully and truly disclose material facts nor circumstances warranting reassessment. The impugned High Court order was left undisturbed and the petition dismissed.
"Delay condoned." Petitioners' counsel heard and record materials reviewed. The Court found "no good ground to interfere with the impugned order passed by the High Court." On that basis, "The Special Leave Petition is, accordingly, dismissed." All pending application(s) stand disposed of. The decision rests on appellate restraint where the High Court's order was not shown to warrant interference on the materials before this Court.
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