https://www.taxtmi.com/caselaws?id=445977 The Bombay HC quashed the reopening of assessment under Section 147, finding no valid reasons to believe income escaped assessment. The assessee had fully disclosed all relevant facts during original assessment proceedings, including detailed breakups of plant and machinery for Section 32AC deductions as requested by the Assessing Officer. The court held that mere change of opinion by revenue authorities, even regarding audit queries about misapplication of Section 32AC provisions, cannot justify reassessment when primary facts were truly and fully disclosed. The AO cannot reopen assessment based on same material to take a different view. en-us Fri, 10 Nov 2023 00:00:00 +0530 Thu, 11 Jan 2024 12:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445977 The Bombay HC quashed the reopening of assessment under Section 147, finding no valid reasons to believe income escaped assessment. The assessee had fully disclosed all relevant facts during original assessment proceedings, including detailed breakups of plant and machinery for Section 32AC deductions as requested by the Assessing Officer. The court held that mere change of opinion by revenue authorities, even regarding audit queries about misapplication of Section 32AC provisions, cannot justify reassessment when primary facts were truly and fully disclosed. The AO cannot reopen assessment based on same material to take a different view. Case-Laws Income Tax Fri, 10 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445977