https://www.taxtmi.com/caselaws?id=757905 The HC quashed a notice issued under Section 148 for reopening assessment beyond four years. The AO had originally scrutinized the assessee's Section 80P deduction claim during assessment proceedings by issuing specific queries, which were responded to before passing the assessment order under Section 143(3). The court held that since all material facts were disclosed during original assessment, the AO lacked jurisdiction to reopen beyond four years under Section 147's proviso. The court found no new tangible material available to the AO, only a change of opinion regarding the Section 80P(2)(d) deduction eligibility, which cannot justify reopening assessment. en-us Fri, 23 Aug 2024 00:00:00 +0530 Tue, 03 Sep 2024 10:06:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757905 The HC quashed a notice issued under Section 148 for reopening assessment beyond four years. The AO had originally scrutinized the assessee's Section 80P deduction claim during assessment proceedings by issuing specific queries, which were responded to before passing the assessment order under Section 143(3). The court held that since all material facts were disclosed during original assessment, the AO lacked jurisdiction to reopen beyond four years under Section 147's proviso. The court found no new tangible material available to the AO, only a change of opinion regarding the Section 80P(2)(d) deduction eligibility, which cannot justify reopening assessment. Case-Laws Income Tax Fri, 23 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757905