https://www.taxtmi.com/highlights?id=84157 AO reopened assessment beyond 4 year period without establishing assessee failed to truly disclose material facts. ITAT quashed reopening, holding AO merely changed opinion without tangible belief of escaped income. PCIT's revision u/s 263 to assess other income was rejected as show-cause didn't specify impugned order date, making action time-barred. Further, PCIT couldn't conclude assessment erroneous for non-consideration of information already possessed by AO while forming reopening belief. Assessee's appeal allowed by ITAT. en-us Fri, 20 Dec 2024 08:46:57 +0530 Fri, 20 Dec 2024 08:46:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=84157 AO reopened assessment beyond 4 year period without establishing assessee failed to truly disclose material facts. ITAT quashed reopening, holding AO merely changed opinion without tangible belief of escaped income. PCIT's revision u/s 263 to assess other income was rejected as show-cause didn't specify impugned order date, making action time-barred. Further, PCIT couldn't conclude assessment erroneous for non-consideration of information already possessed by AO while forming reopening belief. Assessee's appeal allowed by ITAT. Highlights Income Tax Fri, 20 Dec 2024 08:46:57 +0530 https://www.taxtmi.com/highlights?id=84157