https://www.taxtmi.com/caselaws?id=763684 Gujarat HC quashed reassessment notice issued by AO for disallowance under Rule 8D read with Section 14A and depreciation claims. Court held AO lacked jurisdiction as notice was based solely on assessment records without new tangible material, constituting mere change of opinion. Details regarding depreciation and Section 14A disallowance were already scrutinized during regular assessment. Notice issued beyond four-year limitation period without allegation of non-disclosure of material facts violated Section 147 proviso. Court emphasized reassessment requires tangible material showing income escapement, not review of earlier decisions. en-us Wed, 04 Dec 2024 00:00:00 +0530 Tue, 24 Dec 2024 16:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763684 Gujarat HC quashed reassessment notice issued by AO for disallowance under Rule 8D read with Section 14A and depreciation claims. Court held AO lacked jurisdiction as notice was based solely on assessment records without new tangible material, constituting mere change of opinion. Details regarding depreciation and Section 14A disallowance were already scrutinized during regular assessment. Notice issued beyond four-year limitation period without allegation of non-disclosure of material facts violated Section 147 proviso. Court emphasized reassessment requires tangible material showing income escapement, not review of earlier decisions. Case-Laws Income Tax Wed, 04 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763684