https://www.taxtmi.com/caselaws?id=445088 ITAT Guwahati held that reassessment proceedings beyond four years were invalid as the assessee had fully disclosed all material facts during original assessment. The AO had issued notices under section 133(6) to share subscribers during original proceedings and was satisfied with their responses regarding the nature and source of funds. The reopening was based merely on change of opinion rather than failure to disclose facts. The first proviso to section 147 was not satisfied since reasons for reopening had already been addressed in original assessment. The assessee cannot be penalized for AO's wrong inference from disclosed facts. Decision favored assessee. en-us Mon, 25 Sep 2023 00:00:00 +0530 Tue, 31 Oct 2023 09:55:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445088 ITAT Guwahati held that reassessment proceedings beyond four years were invalid as the assessee had fully disclosed all material facts during original assessment. The AO had issued notices under section 133(6) to share subscribers during original proceedings and was satisfied with their responses regarding the nature and source of funds. The reopening was based merely on change of opinion rather than failure to disclose facts. The first proviso to section 147 was not satisfied since reasons for reopening had already been addressed in original assessment. The assessee cannot be penalized for AO's wrong inference from disclosed facts. Decision favored assessee. Case-Laws Income Tax Mon, 25 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445088