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The HC held that reopening an assessment under Section 148 based solely on a change of opinion by the AO is impermissible. The assessee had fully and truthfully disclosed all primary facts, including interest payments, during the original assessment proceedings. The AO's failure to seek further details or draw different inferences does not amount to escapement of income. Since the issue was already considered in the original assessment, the reopening lacked tangible material or justification. Consequently, the HC ruled that the reassessment was invalid, affirming that the duty of disclosure rests only on primary facts and not on directing the AO's inferences. The decision was rendered in favor of the assessee.
The HC held that reopening an assessment under Section 148 based solely on a change of opinion by the AO is impermissible. The assessee had fully and truthfully disclosed all primary facts, including interest payments, during the original assessment proceedings. The AO's failure to seek further details or draw different inferences does not amount to escapement of income. Since the issue was already considered in the original assessment, the reopening lacked tangible material or justification. Consequently, the HC ruled that the reassessment was invalid, affirming that the duty of disclosure rests only on primary facts and not on directing the AO's inferences. The decision was rendered in favor of the assessee.
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