https://www.taxtmi.com/caselaws?id=436932 Re-opening of assessment under section 147 beyond four years was quashed by the HC because the notice relied solely on materials already available in the assessment record concerning an alleged excess bad-debt claim; no fresh tangible material was produced and the AO had considered explanations during original proceedings. The court held the re-opening amounted to an impermissible change of opinion, not permissible ground for reassessment, and therefore ruled in favour of the assessee. en-us Thu, 20 Apr 2023 00:00:00 +0530 Sat, 20 Sep 2025 12:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436932 Re-opening of assessment under section 147 beyond four years was quashed by the HC because the notice relied solely on materials already available in the assessment record concerning an alleged excess bad-debt claim; no fresh tangible material was produced and the AO had considered explanations during original proceedings. The court held the re-opening amounted to an impermissible change of opinion, not permissible ground for reassessment, and therefore ruled in favour of the assessee. Case-Laws Income Tax Thu, 20 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436932