https://www.taxtmi.com/caselaws?id=439966 HC allowed the appeal and quashed proceedings under section 147, holding that the reopening was based on a mere change of opinion rather than any failure to truly and fully disclose material facts or new tangible material showing escaped income. The AO had considered submissions, accepted carried-forward losses, and losses arising on amalgamation retained their extended life; therefore the reassessment attempt impermissibly reviewed the original order. Decision in favour of the assessee. en-us Tue, 27 Jun 2023 00:00:00 +0530 Tue, 18 Nov 2025 11:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439966 HC allowed the appeal and quashed proceedings under section 147, holding that the reopening was based on a mere change of opinion rather than any failure to truly and fully disclose material facts or new tangible material showing escaped income. The AO had considered submissions, accepted carried-forward losses, and losses arising on amalgamation retained their extended life; therefore the reassessment attempt impermissibly reviewed the original order. Decision in favour of the assessee. Case-Laws Income Tax Tue, 27 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439966