https://www.taxtmi.com/caselaws?id=428857 The Tribunal upheld the decision of the CIT(A) that the re-assessment proceedings initiated by the A.O. beyond the four-year period under section 147 of the Income-tax Act were invalid and bad in law. It was found that the A.O. did not provide evidence of the assessee failing to disclose all material facts during the original assessment, leading to the reassessment being solely based on a change of opinion. The Tribunal dismissed the revenue's appeal, affirming that all material facts were disclosed initially, rendering the reassessment unjustified. en-us Tue, 30 Aug 2022 00:00:00 +0530 Wed, 12 Oct 2022 10:01:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428857 The Tribunal upheld the decision of the CIT(A) that the re-assessment proceedings initiated by the A.O. beyond the four-year period under section 147 of the Income-tax Act were invalid and bad in law. It was found that the A.O. did not provide evidence of the assessee failing to disclose all material facts during the original assessment, leading to the reassessment being solely based on a change of opinion. The Tribunal dismissed the revenue's appeal, affirming that all material facts were disclosed initially, rendering the reassessment unjustified. Case-Laws Income Tax Tue, 30 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428857