https://www.taxtmi.com/caselaws?id=263666 A reassessment notice issued after four years was treated as invalid where the assessee had disclosed the service income, deduction basis and supporting material in the original return, audit report and computation. The court noted that the Assessing Officer had already examined the Section 80HHC claim, so the proviso to Section 147 was not met because there was no failure to fully and truly disclose material facts. Reopening based only on a later Supreme Court ruling supplied no fresh tangible material and amounted to an impermissible review or mere change of opinion. The reassessment proceedings were therefore held to be without jurisdiction. en-us Wed, 15 Jul 2015 00:00:00 +0530 Sat, 07 Nov 2015 14:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263666 A reassessment notice issued after four years was treated as invalid where the assessee had disclosed the service income, deduction basis and supporting material in the original return, audit report and computation. The court noted that the Assessing Officer had already examined the Section 80HHC claim, so the proviso to Section 147 was not met because there was no failure to fully and truly disclose material facts. Reopening based only on a later Supreme Court ruling supplied no fresh tangible material and amounted to an impermissible review or mere change of opinion. The reassessment proceedings were therefore held to be without jurisdiction. Case-Laws Income Tax Wed, 15 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263666