https://www.taxtmi.com/caselaws?id=767029 Bombay HC quashed reassessment proceedings under Section 147 initiated after four years. Court held that reassessment notice failed to satisfy jurisdictional requirements as petitioner had fully disclosed material facts during original assessment. The guarantee fee issue was already examined and added to original assessment order, with matter pending before Tribunal. Court found no failure to disclose facts or escaped income, ruling proceedings amounted to impermissible change of opinion. Third proviso to Section 147 barred reassessment on issues pending before appellate authority. Reassessment notice and consequent assessment order quashed as without jurisdiction. en-us Fri, 07 Mar 2025 00:00:00 +0530 Fri, 07 Mar 2025 16:21:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767029 Bombay HC quashed reassessment proceedings under Section 147 initiated after four years. Court held that reassessment notice failed to satisfy jurisdictional requirements as petitioner had fully disclosed material facts during original assessment. The guarantee fee issue was already examined and added to original assessment order, with matter pending before Tribunal. Court found no failure to disclose facts or escaped income, ruling proceedings amounted to impermissible change of opinion. Third proviso to Section 147 barred reassessment on issues pending before appellate authority. Reassessment notice and consequent assessment order quashed as without jurisdiction. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767029