https://www.taxtmi.com/caselaws?id=766328 The HC quashed reassessment proceedings initiated beyond the 4-year limitation period under Section 147. The court held that reopening was barred as the identical issues were already subject to Section 263 revisional proceedings by the same PCIT who later approved the reopening. The third proviso to Section 147 prohibited such proceedings. Additionally, the reassessment failed to satisfy the pre-condition of non-disclosure of material facts, as reasons were based on record verification rather than new information. The court ruled that re-examining issues already decided pursuant to Section 263 directions constituted an impermissible change of opinion. en-us Thu, 20 Feb 2025 00:00:00 +0530 Fri, 21 Feb 2025 11:59:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766328 The HC quashed reassessment proceedings initiated beyond the 4-year limitation period under Section 147. The court held that reopening was barred as the identical issues were already subject to Section 263 revisional proceedings by the same PCIT who later approved the reopening. The third proviso to Section 147 prohibited such proceedings. Additionally, the reassessment failed to satisfy the pre-condition of non-disclosure of material facts, as reasons were based on record verification rather than new information. The court ruled that re-examining issues already decided pursuant to Section 263 directions constituted an impermissible change of opinion. Case-Laws Income Tax Thu, 20 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766328