https://www.taxtmi.com/caselaws?id=402280 Reassessment notices issued beyond four years under the Income-tax Act were unsustainable where the assessee had already disclosed the relevant transactions and the Department relied on the same material examined in earlier proceedings. The reasons recorded showed no fresh tangible material, and there was no allegation that the assessee had failed to fully and truly disclose material facts. The proviso to Section 147 therefore applied, and reopening on an unchanged factual basis amounted to a mere change of opinion, impermissibly treating reassessment as review. The notices were without jurisdiction and liable to be quashed. en-us Mon, 21 Dec 2020 00:00:00 +0530 Mon, 28 Dec 2020 09:46:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402280 Reassessment notices issued beyond four years under the Income-tax Act were unsustainable where the assessee had already disclosed the relevant transactions and the Department relied on the same material examined in earlier proceedings. The reasons recorded showed no fresh tangible material, and there was no allegation that the assessee had failed to fully and truly disclose material facts. The proviso to Section 147 therefore applied, and reopening on an unchanged factual basis amounted to a mere change of opinion, impermissibly treating reassessment as review. The notices were without jurisdiction and liable to be quashed. Case-Laws Income Tax Mon, 21 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402280