https://www.taxtmi.com/caselaws?id=752593 The Bombay HC ruled in favor of a Cyprus tax resident regarding reopening of assessment under section 147 for unexplained NCD investments. During original assessment proceedings, the AO had specifically queried the petitioner about NCD holdings and interest income through section 142(1) notice. The petitioner provided complete details showing unchanged opening and closing NCD stock. The HC held that since the NCD issue was already considered during original assessment when specific queries were raised and answered, the reopening was merely based on AO's change of opinion, which doesn't constitute valid reason to believe income escaped assessment. The assessment reopening was therefore invalid. en-us Tue, 07 May 2024 00:00:00 +0530 Mon, 13 May 2024 17:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752593 The Bombay HC ruled in favor of a Cyprus tax resident regarding reopening of assessment under section 147 for unexplained NCD investments. During original assessment proceedings, the AO had specifically queried the petitioner about NCD holdings and interest income through section 142(1) notice. The petitioner provided complete details showing unchanged opening and closing NCD stock. The HC held that since the NCD issue was already considered during original assessment when specific queries were raised and answered, the reopening was merely based on AO's change of opinion, which doesn't constitute valid reason to believe income escaped assessment. The assessment reopening was therefore invalid. Case-Laws Income Tax Tue, 07 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752593