https://www.taxtmi.com/caselaws?id=373701 A reopening notice issued beyond four years was invalid because the original scrutiny assessment had already examined the assessee's treaty-based exemption claim for interest income, and the assessee had furnished replies, residency documents and supporting details. The Assessing Officer had accepted the claim in the original order, so reopening on the same material amounted to a change of opinion. Since the recorded reasons did not validly allege any failure by the assessee to disclose fully and truly all material facts, the jurisdictional condition for reassessment beyond four years was not met. The Bombay HC therefore quashed the notice in favour of the assessee. en-us Mon, 14 Jan 2019 00:00:00 +0530 Fri, 18 Jan 2019 08:10:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=373701 A reopening notice issued beyond four years was invalid because the original scrutiny assessment had already examined the assessee's treaty-based exemption claim for interest income, and the assessee had furnished replies, residency documents and supporting details. The Assessing Officer had accepted the claim in the original order, so reopening on the same material amounted to a change of opinion. Since the recorded reasons did not validly allege any failure by the assessee to disclose fully and truly all material facts, the jurisdictional condition for reassessment beyond four years was not met. The Bombay HC therefore quashed the notice in favour of the assessee. Case-Laws Income Tax Mon, 14 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=373701