https://www.taxtmi.com/caselaws?id=411978 Reassessment initiated beyond four years was invalid because the Revenue did not establish any failure by the assessee to fully and truly disclose all material facts necessary for assessment. The original scrutiny had already considered the amalgamation, carry-forward losses and unabsorbed depreciation, and the reopening was based on the same material previously examined. A later view treating the transaction as an ordinary takeover rather than an amalgamation was only a different inference from the existing record, not fresh tangible material. The reopening was therefore vitiated by change of opinion, and the reassessment notice and order rejecting objections were quashed. en-us Thu, 26 Aug 2021 00:00:00 +0530 Wed, 17 Nov 2021 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411978 Reassessment initiated beyond four years was invalid because the Revenue did not establish any failure by the assessee to fully and truly disclose all material facts necessary for assessment. The original scrutiny had already considered the amalgamation, carry-forward losses and unabsorbed depreciation, and the reopening was based on the same material previously examined. A later view treating the transaction as an ordinary takeover rather than an amalgamation was only a different inference from the existing record, not fresh tangible material. The reopening was therefore vitiated by change of opinion, and the reassessment notice and order rejecting objections were quashed. Case-Laws Income Tax Thu, 26 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411978