https://www.taxtmi.com/caselaws?id=765950 Reassessment under Sections 147 and 148 was held unsustainable where the assessee had disclosed the relevant facts in the return, balance sheet, and profit and loss account, and the original assessment under Section 143(3) had already considered the issue of interest-free loans to related concerns. The assessing officer had earlier formed a view on commercial expediency and the absence of any basis for disallowance under Section 36(1)(iii). In these circumstances, reopening without any failure of full and true disclosure amounted to an impermissible change of opinion, so the reassessment notice and speaking order could not be sustained. en-us Fri, 24 Jan 2025 00:00:00 +0530 Thu, 13 Feb 2025 08:36:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765950 Reassessment under Sections 147 and 148 was held unsustainable where the assessee had disclosed the relevant facts in the return, balance sheet, and profit and loss account, and the original assessment under Section 143(3) had already considered the issue of interest-free loans to related concerns. The assessing officer had earlier formed a view on commercial expediency and the absence of any basis for disallowance under Section 36(1)(iii). In these circumstances, reopening without any failure of full and true disclosure amounted to an impermissible change of opinion, so the reassessment notice and speaking order could not be sustained. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765950