https://www.taxtmi.com/highlights?id=86248 HC invalidated reassessment notice under s.147 as time-barred and lacking new material evidence. AO's attempt to reopen assessment was based on existing records previously disclosed during s.143(3) assessment, where assessee had furnished complete details regarding Chapter VI-A deductions. Court held no failure by assessee in material fact disclosure. Reopening constituted mere change of opinion as AO relied on already available information without new tangible material, which is legally impermissible. Revenue's reexamination of existing records cannot form basis for reassessment beyond limitation period. Assessment notice quashed. en-us Wed, 05 Mar 2025 07:49:45 +0530 Wed, 05 Mar 2025 07:49:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=86248 HC invalidated reassessment notice under s.147 as time-barred and lacking new material evidence. AO's attempt to reopen assessment was based on existing records previously disclosed during s.143(3) assessment, where assessee had furnished complete details regarding Chapter VI-A deductions. Court held no failure by assessee in material fact disclosure. Reopening constituted mere change of opinion as AO relied on already available information without new tangible material, which is legally impermissible. Revenue's reexamination of existing records cannot form basis for reassessment beyond limitation period. Assessment notice quashed. Highlights Income Tax Wed, 05 Mar 2025 07:49:45 +0530 https://www.taxtmi.com/highlights?id=86248