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HC held that reopening of assessment u/s 147 was impermissible where the taxpayer had fully disclosed all material facts during original assessment proceedings. The AO's attempt to reopen after four years, based on mere change of opinion without tangible evidence of escaped income, was deemed invalid. The court found that purchase deeds for immovable property investments were already submitted during initial assessment, rendering the subsequent reassessment notice unsustainable. Consequently, the impugned notice was quashed, effectively protecting the assessee's original assessment and preventing arbitrary tax reassessment beyond statutory limitations.
HC held that reopening of assessment u/s 147 was impermissible where the taxpayer had fully disclosed all material facts during original assessment proceedings. The AO's attempt to reopen after four years, based on mere change of opinion without tangible evidence of escaped income, was deemed invalid. The court found that purchase deeds for immovable property investments were already submitted during initial assessment, rendering the subsequent reassessment notice unsustainable. Consequently, the impugned notice was quashed, effectively protecting the assessee's original assessment and preventing arbitrary tax reassessment beyond statutory limitations.
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