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HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to disclose material facts fully and truly during original assessment. The reopening attempt by successor AO on previously decided issues amounted to improper exercise of revisionary powers. The court held that mere change of opinion cannot justify reopening beyond 4-year limitation period without new material facts. The Revenue's attempt to reopen assessment based on different interpretation of same facts was deemed invalid, as original assessment decision had considered and accepted assessee's claims. Decision affirmed CIT(A)'s order quashing the reassessment notice.
HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to disclose material facts fully and truly during original assessment. The reopening attempt by successor AO on previously decided issues amounted to improper exercise of revisionary powers. The court held that mere change of opinion cannot justify reopening beyond 4-year limitation period without new material facts. The Revenue's attempt to reopen assessment based on different interpretation of same facts was deemed invalid, as original assessment decision had considered and accepted assessee's claims. Decision affirmed CIT(A)'s order quashing the reassessment notice.
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