https://www.taxtmi.com/caselaws?id=381279 Reassessment was held unsustainable where the assessee had fully disclosed the primary facts, supporting records and computations in the original scrutiny assessment. For the year beyond four years, the proviso to Section 147 was not met because there was no failure to disclose material facts, and the reopening amounted to an impermissible review and change of opinion. For the year within four years, the reopening also failed because it was based only on an audit objection and material already on record, without independent tangible material or fresh reason to believe. The notices and rejection orders were quashed. en-us Tue, 16 Apr 2019 00:00:00 +0530 Mon, 18 May 2020 14:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=381279 Reassessment was held unsustainable where the assessee had fully disclosed the primary facts, supporting records and computations in the original scrutiny assessment. For the year beyond four years, the proviso to Section 147 was not met because there was no failure to disclose material facts, and the reopening amounted to an impermissible review and change of opinion. For the year within four years, the reopening also failed because it was based only on an audit objection and material already on record, without independent tangible material or fresh reason to believe. The notices and rejection orders were quashed. Case-Laws Income Tax Tue, 16 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=381279