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HC invalidated reassessment notice under s.147 as time-barred and lacking new material evidence. AO's attempt to reopen assessment was based on existing records previously disclosed during s.143(3) assessment, where assessee had furnished complete details regarding Chapter VI-A deductions. Court held no failure by assessee in material fact disclosure. Reopening constituted mere change of opinion as AO relied on already available information without new tangible material, which is legally impermissible. Revenue's reexamination of existing records cannot form basis for reassessment beyond limitation period. Assessment notice quashed.
HC invalidated reassessment notice under s.147 as time-barred and lacking new material evidence. AO's attempt to reopen assessment was based on existing records previously disclosed during s.143(3) assessment, where assessee had furnished complete details regarding Chapter VI-A deductions. Court held no failure by assessee in material fact disclosure. Reopening constituted mere change of opinion as AO relied on already available information without new tangible material, which is legally impermissible. Revenue's reexamination of existing records cannot form basis for reassessment beyond limitation period. Assessment notice quashed.
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