https://www.taxtmi.com/caselaws?id=758633 The Kerala HC held that the revenue's notice under Section 148 for reopening assessment was invalid. The department had raised queries about fund accumulation and utilization during original assessment proceedings in 2011, which the assessee had responded to through detailed submissions. Since the assessing officer did not address this issue in the original assessment order despite receiving responses, it was deemed accepted. The HC ruled that issuing a reopening notice in 2016 based on the same grounds constituted a mere change of opinion, which is impermissible. The extended limitation period of six years was not applicable as the assessee had fully disclosed all material facts. The petition was allowed. en-us Fri, 30 Aug 2024 00:00:00 +0530 Mon, 16 Sep 2024 10:59:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758633 The Kerala HC held that the revenue's notice under Section 148 for reopening assessment was invalid. The department had raised queries about fund accumulation and utilization during original assessment proceedings in 2011, which the assessee had responded to through detailed submissions. Since the assessing officer did not address this issue in the original assessment order despite receiving responses, it was deemed accepted. The HC ruled that issuing a reopening notice in 2016 based on the same grounds constituted a mere change of opinion, which is impermissible. The extended limitation period of six years was not applicable as the assessee had fully disclosed all material facts. The petition was allowed. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758633