https://www.taxtmi.com/caselaws?id=396094 The Tribunal quashed the reassessment proceedings under sections 147 and 148 of the Income Tax Act due to the invalidity of reopening beyond four years without any failure on the part of the assessee to disclose material facts. The reassessment was deemed based on a change of opinion. As a result, the appeal of the assessee was allowed. Additionally, the Tribunal upheld the CIT(A)'s decision to allow the set-off of derivative loss against the unexplained cash credit, dismissing the revenue's appeal challenging this set-off. en-us Fri, 12 Jun 2020 00:00:00 +0530 Fri, 19 Jun 2020 17:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396094 The Tribunal quashed the reassessment proceedings under sections 147 and 148 of the Income Tax Act due to the invalidity of reopening beyond four years without any failure on the part of the assessee to disclose material facts. The reassessment was deemed based on a change of opinion. As a result, the appeal of the assessee was allowed. Additionally, the Tribunal upheld the CIT(A)'s decision to allow the set-off of derivative loss against the unexplained cash credit, dismissing the revenue's appeal challenging this set-off. Case-Laws Income Tax Fri, 12 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396094