https://www.taxtmi.com/caselaws?id=460825 The Delhi HC quashed reassessment proceedings under Section 147 of the Income Tax Act, finding they constituted an impermissible change of opinion. The court held that the assessee had made full and true disclosures during original assessment proceedings regarding remittances, TDS, and capital gains. The assessing officer was cognizant of all relevant facts but chose not to make additions or draw adverse inferences. Since no fresh information emerged and the AO's decision was based solely on findings from a subsequent assessment year, the reassessment was invalid. The court emphasized that mere failure to apply legal provisions correctly doesn't justify reassessment when adequate disclosures were made. en-us Wed, 21 Feb 2024 00:00:00 +0530 Sat, 22 Feb 2025 18:13:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460825 The Delhi HC quashed reassessment proceedings under Section 147 of the Income Tax Act, finding they constituted an impermissible change of opinion. The court held that the assessee had made full and true disclosures during original assessment proceedings regarding remittances, TDS, and capital gains. The assessing officer was cognizant of all relevant facts but chose not to make additions or draw adverse inferences. Since no fresh information emerged and the AO's decision was based solely on findings from a subsequent assessment year, the reassessment was invalid. The court emphasized that mere failure to apply legal provisions correctly doesn't justify reassessment when adequate disclosures were made. Case-Laws Income Tax Wed, 21 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460825