https://www.taxtmi.com/caselaws?id=450259 The Bombay HC quashed a notice issued under Section 148 for reopening assessment after four years expired. The court held that recorded reasons failed to allege non-disclosure of material facts by the assessee. Additionally, Section 73 applicability was already considered during original assessment proceedings, as evidenced by the assessee's detailed response and the AO's admission of prior discussion. The court ruled that reopening based merely on change of opinion without proper justification constitutes invalid grounds for believing income escaped assessment. The petition was decided in favor of the assessee. en-us Tue, 27 Feb 2024 00:00:00 +0530 Mon, 09 Jun 2025 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450259 The Bombay HC quashed a notice issued under Section 148 for reopening assessment after four years expired. The court held that recorded reasons failed to allege non-disclosure of material facts by the assessee. Additionally, Section 73 applicability was already considered during original assessment proceedings, as evidenced by the assessee's detailed response and the AO's admission of prior discussion. The court ruled that reopening based merely on change of opinion without proper justification constitutes invalid grounds for believing income escaped assessment. The petition was decided in favor of the assessee. Case-Laws Income Tax Tue, 27 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450259