https://www.taxtmi.com/caselaws?id=460588 The Bombay HC held that the reopening of assessment was invalid as it constituted a mere change of opinion rather than discovery of new material or failure to disclose. The court found that section 43CA(3) was incorrectly applied since the condition requiring consideration received through non-cash modes was not satisfied. The assessee had fully disclosed all material facts and responded to queries raised during assessment. The AO's notice was deemed a review of the earlier decision without specific reasons or new material discovery. The petition was decided in favor of the assessee. en-us Wed, 11 Jan 2023 00:00:00 +0530 Mon, 03 Feb 2025 14:57:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460588 The Bombay HC held that the reopening of assessment was invalid as it constituted a mere change of opinion rather than discovery of new material or failure to disclose. The court found that section 43CA(3) was incorrectly applied since the condition requiring consideration received through non-cash modes was not satisfied. The assessee had fully disclosed all material facts and responded to queries raised during assessment. The AO's notice was deemed a review of the earlier decision without specific reasons or new material discovery. The petition was decided in favor of the assessee. Case-Laws Income Tax Wed, 11 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460588