https://www.taxtmi.com/caselaws?id=757903 The Gujarat HC quashed a reassessment notice issued u/s 147 beyond four years. The revenue sought to reopen assessment based on audit objections regarding TP adjustment mark-up reduction from 12% to 9.17% (considering foreign exchange risk) and reduced exchange gain on share sale. The court held that audit objections constituted mere change of opinion without any failure by the assessee to make full and true disclosure of material facts. Since the assessee had made complete disclosure in original assessment and revised return, reassessment beyond four years was impermissible under proviso to Section 147. The petition was allowed in favor of the assessee. en-us Tue, 13 Aug 2024 00:00:00 +0530 Wed, 04 Sep 2024 08:20:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757903 The Gujarat HC quashed a reassessment notice issued u/s 147 beyond four years. The revenue sought to reopen assessment based on audit objections regarding TP adjustment mark-up reduction from 12% to 9.17% (considering foreign exchange risk) and reduced exchange gain on share sale. The court held that audit objections constituted mere change of opinion without any failure by the assessee to make full and true disclosure of material facts. Since the assessee had made complete disclosure in original assessment and revised return, reassessment beyond four years was impermissible under proviso to Section 147. The petition was allowed in favor of the assessee. Case-Laws Income Tax Tue, 13 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757903