https://www.taxtmi.com/caselaws?id=459034 Gujarat HC held that reopening assessment under Section 148 was invalid where disallowance under Section 14A had already been considered in original assessment and subsequently merged with CIT (Appeals) order. The court ruled that AO lacked jurisdiction to reopen assessment on same grounds without fresh material, constituting impermissible change of opinion. Since notice was issued beyond four years without establishing failure to disclose material facts fully, the reopening violated Section 147 proviso requirements. Assessment reopening was quashed in favor of assessee. en-us Tue, 30 Jan 2024 00:00:00 +0530 Fri, 27 Mar 2026 15:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459034 Gujarat HC held that reopening assessment under Section 148 was invalid where disallowance under Section 14A had already been considered in original assessment and subsequently merged with CIT (Appeals) order. The court ruled that AO lacked jurisdiction to reopen assessment on same grounds without fresh material, constituting impermissible change of opinion. Since notice was issued beyond four years without establishing failure to disclose material facts fully, the reopening violated Section 147 proviso requirements. Assessment reopening was quashed in favor of assessee. Case-Laws Income Tax Tue, 30 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459034