https://www.taxtmi.com/caselaws?id=450373 The Gujarat HC allowed the petition challenging reopening of assessment under Section 147. The assessee had claimed exemption under Section 54F for AY 2013-14 and purchased residential plots, providing details during regular assessment for AY 2015-16. The HC held that the AO cannot re-appreciate the same facts already considered in AY 2015-16 to disallow Section 54F exemption for reopening AY 2016-17. The condition precedent for exercising jurisdiction under Section 147 did not exist, making the AO's notice under Section 148 invalid. The court quashed the impugned notice and subsequent actions, ruling there was lack of jurisdiction to reopen assessment on mere change of opinion. en-us Fri, 23 Feb 2024 00:00:00 +0530 Wed, 09 Jul 2025 16:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450373 The Gujarat HC allowed the petition challenging reopening of assessment under Section 147. The assessee had claimed exemption under Section 54F for AY 2013-14 and purchased residential plots, providing details during regular assessment for AY 2015-16. The HC held that the AO cannot re-appreciate the same facts already considered in AY 2015-16 to disallow Section 54F exemption for reopening AY 2016-17. The condition precedent for exercising jurisdiction under Section 147 did not exist, making the AO's notice under Section 148 invalid. The court quashed the impugned notice and subsequent actions, ruling there was lack of jurisdiction to reopen assessment on mere change of opinion. Case-Laws Income Tax Fri, 23 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450373