https://www.taxtmi.com/caselaws?id=763637 Bombay HC held that AO lacked jurisdiction to reopen assessment beyond four years under Section 147. The court found that assessee had fully disclosed all material facts during original assessment, and AO's reasons for reopening were based on same materials already available during Section 143(3) assessment. This constituted impermissible change of opinion rather than discovery of new evidence. The reopening violated first proviso to Section 147 and amounted to manifest arbitrariness. Court exercised judicial review powers under Article 226 to quash the Section 148 notice, rejecting revenue's contentions against writ jurisdiction. en-us Fri, 20 Dec 2024 00:00:00 +0530 Tue, 24 Dec 2024 08:28:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763637 Bombay HC held that AO lacked jurisdiction to reopen assessment beyond four years under Section 147. The court found that assessee had fully disclosed all material facts during original assessment, and AO's reasons for reopening were based on same materials already available during Section 143(3) assessment. This constituted impermissible change of opinion rather than discovery of new evidence. The reopening violated first proviso to Section 147 and amounted to manifest arbitrariness. Court exercised judicial review powers under Article 226 to quash the Section 148 notice, rejecting revenue's contentions against writ jurisdiction. Case-Laws Income Tax Fri, 20 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763637