https://www.taxtmi.com/caselaws?id=763466 The ITAT Kolkata quashed the reopening of assessment beyond four years, finding the AO failed to specify which material facts were not disclosed by the assessee during scrutiny assessment under section 143(3). The tribunal held that reopening was based on change of opinion without tangible material to form belief that income escaped assessment. The assessee had disclosed sale of investments credited to accounts, and the AO possessed no credible information demonstrating undisclosed facts. Additionally, the PCIT's revision under section 263 was quashed due to vague show-cause notice failing to specify the assessment order's date being revised, and because the AO already possessed the information before forming prima facie opinion about income escapement. en-us Thu, 22 Aug 2024 00:00:00 +0530 Fri, 20 Dec 2024 08:46:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763466 The ITAT Kolkata quashed the reopening of assessment beyond four years, finding the AO failed to specify which material facts were not disclosed by the assessee during scrutiny assessment under section 143(3). The tribunal held that reopening was based on change of opinion without tangible material to form belief that income escaped assessment. The assessee had disclosed sale of investments credited to accounts, and the AO possessed no credible information demonstrating undisclosed facts. Additionally, the PCIT's revision under section 263 was quashed due to vague show-cause notice failing to specify the assessment order's date being revised, and because the AO already possessed the information before forming prima facie opinion about income escapement. Case-Laws Income Tax Thu, 22 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763466