https://www.taxtmi.com/caselaws?id=758667 The HC quashed a reassessment notice u/s 147 where the petitioner had fully disclosed all material facts during regular assessment. The court held that the AO's belief was based solely on record verification without fresh tangible material, constituting a mere change of opinion. Following Kelvinator precedent, the court distinguished between review and reassessment powers, emphasizing that reassessment requires fulfillment of pre-conditions. The concept of change of opinion serves as an in-built test to prevent abuse of power by AOs. The petition was decided in favor of the assessee. en-us Mon, 15 Apr 2024 00:00:00 +0530 Tue, 17 Sep 2024 08:37:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758667 The HC quashed a reassessment notice u/s 147 where the petitioner had fully disclosed all material facts during regular assessment. The court held that the AO's belief was based solely on record verification without fresh tangible material, constituting a mere change of opinion. Following Kelvinator precedent, the court distinguished between review and reassessment powers, emphasizing that reassessment requires fulfillment of pre-conditions. The concept of change of opinion serves as an in-built test to prevent abuse of power by AOs. The petition was decided in favor of the assessee. Case-Laws Income Tax Mon, 15 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758667