https://www.taxtmi.com/caselaws?id=266909 The court quashed the notice for reopening the assessment for the assessment year 2007-08 as it was issued beyond the permissible four-year period and lacked grounds for reopening based on failure to disclose material facts. The court found the petitioner had fully disclosed all necessary information during the original assessment, rendering the reopening attempt as a mere change of opinion. The court did not delve into the DTAA applicability due to the invalidity of the reopening notice. The petition was disposed of in favor of the petitioner, with no costs awarded. en-us Tue, 22 Apr 2014 00:00:00 +0530 Mon, 26 Oct 2015 10:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=266909 The court quashed the notice for reopening the assessment for the assessment year 2007-08 as it was issued beyond the permissible four-year period and lacked grounds for reopening based on failure to disclose material facts. The court found the petitioner had fully disclosed all necessary information during the original assessment, rendering the reopening attempt as a mere change of opinion. The court did not delve into the DTAA applicability due to the invalidity of the reopening notice. The petition was disposed of in favor of the petitioner, with no costs awarded. Case-Laws Income Tax Tue, 22 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=266909