https://www.taxtmi.com/caselaws?id=242913 Rule 27 of the Income-tax (Appellate Tribunal) Rules, 1963 allows a respondent to support the order appealed against on a ground decided against it, even without filing a cross objection; the assessee was therefore entitled to raise the jurisdictional challenge to reopening before the Tribunal. Reassessment beyond four years from the end of the assessment year under Section 147 is impermissible unless the recorded reasons show failure by the assessee to fully and truly disclose material facts necessary for assessment. Where the original assessment was under Section 143(3), the relevant facts had been disclosed, and reopening was based on the same material without tangible new material, it amounted to a mere change of opinion and could not be sustained. en-us Thu, 05 Dec 2013 00:00:00 +0530 Thu, 23 Jan 2014 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242913 Rule 27 of the Income-tax (Appellate Tribunal) Rules, 1963 allows a respondent to support the order appealed against on a ground decided against it, even without filing a cross objection; the assessee was therefore entitled to raise the jurisdictional challenge to reopening before the Tribunal. Reassessment beyond four years from the end of the assessment year under Section 147 is impermissible unless the recorded reasons show failure by the assessee to fully and truly disclose material facts necessary for assessment. Where the original assessment was under Section 143(3), the relevant facts had been disclosed, and reopening was based on the same material without tangible new material, it amounted to a mere change of opinion and could not be sustained. Case-Laws Income Tax Thu, 05 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242913