https://www.taxtmi.com/caselaws?id=753237 The ITAT Nagpur held that reassessment proceedings initiated beyond four years were invalid as they constituted a mere change of opinion. The AO had examined vehicle sale agreements and made additions under section 68 during original assessment proceedings. Subsequently, without new evidence, the AO issued notice under section 148 alleging escaped capital gains assessment on the same vehicle sales. Since the AO failed to allege non-disclosure of material facts by the assessee and relied on previously examined documents, the reopening was deemed impermissible under section 147 proviso. The appeal was decided in favor of the assessee. en-us Tue, 09 Jan 2024 00:00:00 +0530 Wed, 29 May 2024 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753237 The ITAT Nagpur held that reassessment proceedings initiated beyond four years were invalid as they constituted a mere change of opinion. The AO had examined vehicle sale agreements and made additions under section 68 during original assessment proceedings. Subsequently, without new evidence, the AO issued notice under section 148 alleging escaped capital gains assessment on the same vehicle sales. Since the AO failed to allege non-disclosure of material facts by the assessee and relied on previously examined documents, the reopening was deemed impermissible under section 147 proviso. The appeal was decided in favor of the assessee. Case-Laws Income Tax Tue, 09 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753237