https://www.taxtmi.com/caselaws?id=765233 Gujarat HC dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment u/s 147. Court held that reopening assessment beyond four years without new material facts constituted mere change of opinion by successor AO. The original assessment had accepted assessee's claim regarding VAT payment after considering documents. Notice u/s 148 on same issue without recording reasons for failure to disclose material facts was invalid. Reassessment amounted to assuming revisionary powers not permitted under law. Court emphasized that statutory power to reopen assessments must be exercised sparingly with due application of mind, otherwise it places unrestricted review power in assessing authorities' hands. Reopening found unsustainable and dismissed as devoid of merit. en-us Fri, 17 Jan 2025 00:00:00 +0530 Tue, 28 Jan 2025 08:24:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765233 Gujarat HC dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment u/s 147. Court held that reopening assessment beyond four years without new material facts constituted mere change of opinion by successor AO. The original assessment had accepted assessee's claim regarding VAT payment after considering documents. Notice u/s 148 on same issue without recording reasons for failure to disclose material facts was invalid. Reassessment amounted to assuming revisionary powers not permitted under law. Court emphasized that statutory power to reopen assessments must be exercised sparingly with due application of mind, otherwise it places unrestricted review power in assessing authorities' hands. Reopening found unsustainable and dismissed as devoid of merit. Case-Laws Income Tax Fri, 17 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765233