https://www.taxtmi.com/caselaws?id=449318 The Bombay HC quashed a reassessment notice issued after four years, holding it was based on change of opinion rather than failure to disclose material facts. The court found that all primary facts were disclosed in the original return and the assessing officer had examined the same issues during original assessment proceedings. Following SC precedents in Gemini Leather Stores and Calcutta Discount Co., the court ruled that once primary facts are disclosed, the assessee's duty is complete and the officer cannot reopen assessment due to his own oversight or different interpretation of disclosed facts. en-us Tue, 06 Feb 2024 00:00:00 +0530 Wed, 28 Aug 2024 11:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449318 The Bombay HC quashed a reassessment notice issued after four years, holding it was based on change of opinion rather than failure to disclose material facts. The court found that all primary facts were disclosed in the original return and the assessing officer had examined the same issues during original assessment proceedings. Following SC precedents in Gemini Leather Stores and Calcutta Discount Co., the court ruled that once primary facts are disclosed, the assessee's duty is complete and the officer cannot reopen assessment due to his own oversight or different interpretation of disclosed facts. Case-Laws Income Tax Tue, 06 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449318