https://www.taxtmi.com/caselaws?id=448517 The Bombay HC quashed the reopening of assessment under section 147, finding that the AO lacked valid reasons to believe income had escaped assessment. The petitioner had fully disclosed compensation received for wharf damages in financial statements. The AO possessed all primary facts and failed to conduct proper inquiry during original assessment. The reopening was based solely on petitioner's own disclosures without any new tangible information, constituting an impermissible change of opinion. The section 148 notice, rejection of objections, and draft assessment order were consequently quashed. en-us Mon, 15 Jan 2024 00:00:00 +0530 Fri, 03 May 2024 10:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448517 The Bombay HC quashed the reopening of assessment under section 147, finding that the AO lacked valid reasons to believe income had escaped assessment. The petitioner had fully disclosed compensation received for wharf damages in financial statements. The AO possessed all primary facts and failed to conduct proper inquiry during original assessment. The reopening was based solely on petitioner's own disclosures without any new tangible information, constituting an impermissible change of opinion. The section 148 notice, rejection of objections, and draft assessment order were consequently quashed. Case-Laws Income Tax Mon, 15 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448517