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HC quashed reopening notices under Section 147 for assessment years 2013-14 and 2014-15, holding that AO failed to establish non-disclosure of material facts by petitioner. For AY 2013-14, petitioner had fully disclosed dividend income from BPCL Trust in return, annual report, and Section 14A response. AO's subsequent view that trust distributions don't qualify for Section 10(34) exemption constituted impermissible "change of opinion" rather than income escaping assessment. For AY 2014-15, AO's challenge to Section 32AC deduction was similarly based on already-disclosed facts, representing change of opinion. Court emphasized that mere disagreement with earlier assessment cannot justify reopening after four years when scrutiny assessment under Section 143(3) already conducted and assessee disclosed all material facts. Notices set aside as legally unsustainable.
HC quashed reopening notices under Section 147 for assessment years 2013-14 and 2014-15, holding that AO failed to establish non-disclosure of material facts by petitioner. For AY 2013-14, petitioner had fully disclosed dividend income from BPCL Trust in return, annual report, and Section 14A response. AO's subsequent view that trust distributions don't qualify for Section 10(34) exemption constituted impermissible "change of opinion" rather than income escaping assessment. For AY 2014-15, AO's challenge to Section 32AC deduction was similarly based on already-disclosed facts, representing change of opinion. Court emphasized that mere disagreement with earlier assessment cannot justify reopening after four years when scrutiny assessment under Section 143(3) already conducted and assessee disclosed all material facts. Notices set aside as legally unsustainable.
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