https://www.taxtmi.com/caselaws?id=459617 The Rajasthan HC held that reassessment proceedings under sections 147 and 148 were time-barred and invalid. The court found that the assessee had fully disclosed all material facts including capital gains and FDR details, which were verified by the Assessing Officer. The notice was based on re-appreciation of existing material rather than fresh information, constituting a mere change of opinion. Since there was no failure to disclose material facts and no fresh evidence justifying reopening, the extended limitation period under the first proviso to Section 147 did not apply. The writ petition was allowed. en-us Mon, 09 Sep 2024 00:00:00 +0530 Thu, 19 Dec 2024 18:58:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459617 The Rajasthan HC held that reassessment proceedings under sections 147 and 148 were time-barred and invalid. The court found that the assessee had fully disclosed all material facts including capital gains and FDR details, which were verified by the Assessing Officer. The notice was based on re-appreciation of existing material rather than fresh information, constituting a mere change of opinion. Since there was no failure to disclose material facts and no fresh evidence justifying reopening, the extended limitation period under the first proviso to Section 147 did not apply. The writ petition was allowed. Case-Laws Income Tax Mon, 09 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459617