https://www.taxtmi.com/caselaws?id=325841 Reopening of an assessment cannot rest on a mere change of opinion when the Assessing Officer had already examined the relevant agreement, vouchers, India-specific expenses and loss computation in the original assessment; reopening on a fresh view of the same material is impermissible. Where four years have passed from the end of the assessment year, reassessment is also barred unless the assessee failed to fully and truly disclose all material facts necessary for assessment. On the facts stated, the disclosures were complete, no suppression was shown, and the reassessment notice was quashed. en-us Mon, 21 Mar 2016 00:00:00 +0530 Wed, 04 May 2016 14:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325841 Reopening of an assessment cannot rest on a mere change of opinion when the Assessing Officer had already examined the relevant agreement, vouchers, India-specific expenses and loss computation in the original assessment; reopening on a fresh view of the same material is impermissible. Where four years have passed from the end of the assessment year, reassessment is also barred unless the assessee failed to fully and truly disclose all material facts necessary for assessment. On the facts stated, the disclosures were complete, no suppression was shown, and the reassessment notice was quashed. Case-Laws Income Tax Mon, 21 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325841