https://www.taxtmi.com/caselaws?id=346797 Reopening of assessment was invalid where the recorded reasons did not state any specific failure to fully and truly disclose material facts relating to DTAA benefits. The assessee had already disclosed UAE tax residence and related passport details in the original scrutiny assessment, and the reassessment was triggered only by absence of a Tax Residency Certificate, which was not then a statutory requirement. Since the validity of reassessment must be judged only from the recorded reasons and cannot be supported by later supplementation, the court held that the notice was based on an impermissible change of opinion. The impugned notices and order were quashed. en-us Tue, 25 Jul 2017 00:00:00 +0530 Fri, 21 Jun 2019 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346797 Reopening of assessment was invalid where the recorded reasons did not state any specific failure to fully and truly disclose material facts relating to DTAA benefits. The assessee had already disclosed UAE tax residence and related passport details in the original scrutiny assessment, and the reassessment was triggered only by absence of a Tax Residency Certificate, which was not then a statutory requirement. Since the validity of reassessment must be judged only from the recorded reasons and cannot be supported by later supplementation, the court held that the notice was based on an impermissible change of opinion. The impugned notices and order were quashed. Case-Laws Income Tax Tue, 25 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346797