https://www.taxtmi.com/caselaws?id=756334 The ITAT Mumbai held that the reopening of assessment under section 147 was invalid on multiple grounds. The AO failed to record in the reasons that the assessee failed to disclose fully and truly all material facts necessary for assessment, making the reopening bad in law. Additionally, this constituted a second round of reassessment proceedings where the AO had previously accepted the share capital and premium receipts in the first reopening completed in 2015. The second reopening was based merely on a change of opinion following investigation wing reports and survey statements, which lack evidentiary value and do not constitute tangible material. The tribunal ruled in favor of the assessee, quashing the impugned assessment order. en-us Thu, 30 May 2024 00:00:00 +0530 Thu, 01 Aug 2024 08:32:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756334 The ITAT Mumbai held that the reopening of assessment under section 147 was invalid on multiple grounds. The AO failed to record in the reasons that the assessee failed to disclose fully and truly all material facts necessary for assessment, making the reopening bad in law. Additionally, this constituted a second round of reassessment proceedings where the AO had previously accepted the share capital and premium receipts in the first reopening completed in 2015. The second reopening was based merely on a change of opinion following investigation wing reports and survey statements, which lack evidentiary value and do not constitute tangible material. The tribunal ruled in favor of the assessee, quashing the impugned assessment order. Case-Laws Income Tax Thu, 30 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756334