https://www.taxtmi.com/caselaws?id=761449 Delhi HC held that reassessment proceedings under Section 147 were invalid due to absence of fresh tangible material and failure to establish non-disclosure by the assessee. The court found that the AO's reasons merely reflected a change of opinion regarding DAP and production/translation expenses, which cannot justify reopening beyond four years. Since identical expenses were allowed in subsequent assessment years without disallowance, the basis for "reasons to believe" no longer existed. The reassessment was quashed as bad in law, with the court ruling in favor of the assessee. en-us Fri, 08 Nov 2024 00:00:00 +0530 Fri, 06 Mar 2026 11:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761449 Delhi HC held that reassessment proceedings under Section 147 were invalid due to absence of fresh tangible material and failure to establish non-disclosure by the assessee. The court found that the AO's reasons merely reflected a change of opinion regarding DAP and production/translation expenses, which cannot justify reopening beyond four years. Since identical expenses were allowed in subsequent assessment years without disallowance, the basis for "reasons to believe" no longer existed. The reassessment was quashed as bad in law, with the court ruling in favor of the assessee. Case-Laws Income Tax Fri, 08 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761449