https://www.taxtmi.com/caselaws?id=449317 The Bombay HC held that reopening of assessment under Section 147 after four years was invalid as it was based merely on change of opinion. The assessee claimed they never owned the disputed properties and acted only as a confirming party in sale agreements between original tenants and purchasers. The AO had raised queries about these transactions during original assessment proceedings and the assessee had responded with supporting documents. Since the AO had already considered these matters during original assessment, the reopening was not justified. The court ruled that change of opinion does not constitute valid reasons to believe income escaped assessment. The petition was decided in favor of the assessee. en-us Mon, 05 Feb 2024 00:00:00 +0530 Fri, 09 Feb 2024 07:22:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449317 The Bombay HC held that reopening of assessment under Section 147 after four years was invalid as it was based merely on change of opinion. The assessee claimed they never owned the disputed properties and acted only as a confirming party in sale agreements between original tenants and purchasers. The AO had raised queries about these transactions during original assessment proceedings and the assessee had responded with supporting documents. Since the AO had already considered these matters during original assessment, the reopening was not justified. The court ruled that change of opinion does not constitute valid reasons to believe income escaped assessment. The petition was decided in favor of the assessee. Case-Laws Income Tax Mon, 05 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449317