https://www.taxtmi.com/caselaws?id=755924 Gujarat HC held that reopening assessment u/s 147 based on differential amounts between balance-sheet and profit-loss account constituted mere change of opinion. The AO had originally conducted scrutiny assessment u/s 143(3) with full access to all relevant documents including balance-sheet and profit-loss account. Since petitioner had fully disclosed all material facts during original assessment and no new tangible material emerged, issuing notice u/s 148 beyond four years was impermissible. The court emphasized that change of opinion without fresh evidence cannot justify reopening. Assessee's appeal was allowed. en-us Tue, 09 Jul 2024 00:00:00 +0530 Tue, 23 Jul 2024 08:50:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755924 Gujarat HC held that reopening assessment u/s 147 based on differential amounts between balance-sheet and profit-loss account constituted mere change of opinion. The AO had originally conducted scrutiny assessment u/s 143(3) with full access to all relevant documents including balance-sheet and profit-loss account. Since petitioner had fully disclosed all material facts during original assessment and no new tangible material emerged, issuing notice u/s 148 beyond four years was impermissible. The court emphasized that change of opinion without fresh evidence cannot justify reopening. Assessee's appeal was allowed. Case-Laws Income Tax Tue, 09 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755924