https://www.taxtmi.com/caselaws?id=765622 The AP HC ruled in favor of the assessee regarding reopening of assessment proceedings. The court held that notices issued after four years without fresh information or material violated section 147 of the Income Tax Act, 1961. The AO lacked power to review and the action constituted mere change of opinion, not valid grounds for reopening. Since the assessee disclosed full details in the return and provided all relevant documents, the AO could not assume jurisdiction under section 147, particularly after the four-year limitation period for assessments made under section 143(3). The court found no tangible material indicating income escapement from assessment. en-us Wed, 29 Jan 2025 00:00:00 +0530 Wed, 05 Feb 2025 08:38:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765622 The AP HC ruled in favor of the assessee regarding reopening of assessment proceedings. The court held that notices issued after four years without fresh information or material violated section 147 of the Income Tax Act, 1961. The AO lacked power to review and the action constituted mere change of opinion, not valid grounds for reopening. Since the assessee disclosed full details in the return and provided all relevant documents, the AO could not assume jurisdiction under section 147, particularly after the four-year limitation period for assessments made under section 143(3). The court found no tangible material indicating income escapement from assessment. Case-Laws Income Tax Wed, 29 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765622