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Re-opening of assessment u/s 147 - notice beyond period of four years - change in the opinion or a later decision on the legal aspects - The High court finds no evidence of failure on the part of the assessee to disclose relevant information during the original assessment. - The court declares the re-opening of assessments in all three cases as incompetent and sets aside the notices and assessment orders. It confirms the assessments made under Section 143 for the relevant assessment years. The writ petitions are thus allowed accordingly.
Re-opening of assessment u/s 147 - notice beyond period of four years - change in the opinion or a later decision on the legal aspects - The High court finds no evidence of failure on the part of the assessee to disclose relevant information during the original assessment. - The court declares the re-opening of assessments in all three cases as incompetent and sets aside the notices and assessment orders. It confirms the assessments made under Section 143 for the relevant assessment years. The writ petitions are thus allowed accordingly.
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