https://www.taxtmi.com/caselaws?id=460072 The HC quashed the reopening of the tax assessment under Section 147 of the Income Tax Act for the assessment year 2000-01. The court determined that the reopening was invalid as it was based on a change of opinion rather than a failure by the assessee to disclose material facts fully and truly. The court emphasized that reopening after four years requires evidence of such failure, which was absent in this case, as all relevant materials were already disclosed during the original assessment. The reassessment was not justified, and the merits of the case were not addressed due to the jurisdictional grounds. en-us Fri, 29 Apr 2011 00:00:00 +0530 Fri, 10 Jan 2025 12:01:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460072 The HC quashed the reopening of the tax assessment under Section 147 of the Income Tax Act for the assessment year 2000-01. The court determined that the reopening was invalid as it was based on a change of opinion rather than a failure by the assessee to disclose material facts fully and truly. The court emphasized that reopening after four years requires evidence of such failure, which was absent in this case, as all relevant materials were already disclosed during the original assessment. The reassessment was not justified, and the merits of the case were not addressed due to the jurisdictional grounds. Case-Laws Income Tax Fri, 29 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460072