https://www.taxtmi.com/caselaws?id=752175 HC allows taxpayer's challenge to reopening under s.147/s.148. Court finds revenue lacked fresh tangible material and relied on information available during original assessment; issue of s.14A disallowance read with Rule 8D was already considered at s.143(3) assessment. Reopening after four years therefore amounted to change of opinion and contravened proviso to s.147 since the assessee had truly and fully disclosed material facts. Notice under s.148 quashed and reassessment held impermissible; relief granted to the assessee. en-us Wed, 24 Apr 2024 00:00:00 +0530 Mon, 01 Sep 2025 10:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752175 HC allows taxpayer's challenge to reopening under s.147/s.148. Court finds revenue lacked fresh tangible material and relied on information available during original assessment; issue of s.14A disallowance read with Rule 8D was already considered at s.143(3) assessment. Reopening after four years therefore amounted to change of opinion and contravened proviso to s.147 since the assessee had truly and fully disclosed material facts. Notice under s.148 quashed and reassessment held impermissible; relief granted to the assessee. Case-Laws Income Tax Wed, 24 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752175