https://www.taxtmi.com/caselaws?id=759872 The ITAT Mumbai quashed reassessment proceedings under Section 147, finding the AO lacked valid "reason to believe" for reopening assessment beyond four years. The tribunal held that reopening based on deemed dividend under Section 2(22)(e) constituted mere change of opinion without new tangible material. The AO had applied fresh mind to same facts available during original scrutiny assessment under Section 143(3), failing to establish the four essential elements required for valid reassessment: tangible material showing escaped income, nexus between material and belief, application of mind, and reasonable inference of escapement. en-us Mon, 16 Sep 2024 00:00:00 +0530 Thu, 10 Oct 2024 08:27:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759872 The ITAT Mumbai quashed reassessment proceedings under Section 147, finding the AO lacked valid "reason to believe" for reopening assessment beyond four years. The tribunal held that reopening based on deemed dividend under Section 2(22)(e) constituted mere change of opinion without new tangible material. The AO had applied fresh mind to same facts available during original scrutiny assessment under Section 143(3), failing to establish the four essential elements required for valid reassessment: tangible material showing escaped income, nexus between material and belief, application of mind, and reasonable inference of escapement. Case-Laws Income Tax Mon, 16 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759872