https://www.taxtmi.com/caselaws?id=753958 The ITAT Amritsar quashed a reopening assessment under section 147 issued after four years. The appellant had disclosed disputed cash deposits in bank statements and balance sheets filed with the original return, which were considered by the AO in the section 143(3) assessment. The tribunal held that since there was no failure to disclose material facts truly and fully, the reopening was barred by the first proviso to section 147. The AO merely acted on information already on record from the original assessment, constituting a change of opinion rather than valid grounds for reopening. The assessment order was declared bad in law and quashed. en-us Tue, 07 May 2024 00:00:00 +0530 Thu, 13 Jun 2024 11:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753958 The ITAT Amritsar quashed a reopening assessment under section 147 issued after four years. The appellant had disclosed disputed cash deposits in bank statements and balance sheets filed with the original return, which were considered by the AO in the section 143(3) assessment. The tribunal held that since there was no failure to disclose material facts truly and fully, the reopening was barred by the first proviso to section 147. The AO merely acted on information already on record from the original assessment, constituting a change of opinion rather than valid grounds for reopening. The assessment order was declared bad in law and quashed. Case-Laws Income Tax Tue, 07 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753958