https://www.taxtmi.com/caselaws?id=212049 The Bombay HC set aside a notice issued under section 148 and the subsequent assessment order where the AO attempted to reopen an assessment for AY 2005-06 beyond the four-year limitation period. The AO sought to reopen based on the assessee's claimed melting loss of 7.75% being higher than industry standards. The HC held that without any allegation of failure by the assessee to fully and truly disclose material facts, the reopening constituted merely a change of opinion, which is impermissible. The case was decided in favor of the assessee. en-us Fri, 30 Mar 2012 00:00:00 +0530 Sat, 31 May 2025 10:18:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212049 The Bombay HC set aside a notice issued under section 148 and the subsequent assessment order where the AO attempted to reopen an assessment for AY 2005-06 beyond the four-year limitation period. The AO sought to reopen based on the assessee's claimed melting loss of 7.75% being higher than industry standards. The HC held that without any allegation of failure by the assessee to fully and truly disclose material facts, the reopening constituted merely a change of opinion, which is impermissible. The case was decided in favor of the assessee. Case-Laws Income Tax Fri, 30 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212049