https://www.taxtmi.com/highlights?id=77427 Reopening of Assessment u/s 147 - investment in NCDs unexplained - difference between accrual of income and receipt of income - reopening after the expiry of four years - Petitioner is a tax resident of Cyprus - The Bombay High Court quashed the reopening notice dated 30th March 2021 and subsequent orders, holding that the reopening of the assessment was based on a mere change of opinion, which is not a valid ground for reassessment. The Court emphasized that all material facts were disclosed by the Petitioner during the original assessment proceedings, and any reassessment after four years is impermissible without a failure to disclose such facts. Furthermore, the Court upheld the Petitioner's argument that under the India-Cyprus DTAA, interest income is taxable only upon receipt, which was not adequately addressed by the Respondents. en-us Tue, 14 May 2024 06:54:23 +0530 Tue, 14 May 2024 06:54:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=77427 Reopening of Assessment u/s 147 - investment in NCDs unexplained - difference between accrual of income and receipt of income - reopening after the expiry of four years - Petitioner is a tax resident of Cyprus - The Bombay High Court quashed the reopening notice dated 30th March 2021 and subsequent orders, holding that the reopening of the assessment was based on a mere change of opinion, which is not a valid ground for reassessment. The Court emphasized that all material facts were disclosed by the Petitioner during the original assessment proceedings, and any reassessment after four years is impermissible without a failure to disclose such facts. Furthermore, the Court upheld the Petitioner's argument that under the India-Cyprus DTAA, interest income is taxable only upon receipt, which was not adequately addressed by the Respondents. Highlights Income Tax Tue, 14 May 2024 06:54:23 +0530 https://www.taxtmi.com/highlights?id=77427