https://www.taxtmi.com/caselaws?id=767629 Reopening of an assessment beyond four years is barred where the assessee has already disclosed all material facts and the issue was examined during scrutiny. The text states that the recorded reasons showed queries on promotional expenses, partial disallowance in the original assessment, and disclosure of relevant submissions and CBDT circular material. In those circumstances, the first proviso to Section 147 was not satisfied, so the reassessment amounted to a mere change of opinion and an impermissible review of a completed assessment. It also notes that the same issue had already been carried in appeal, further supporting invalidity of the notice. en-us Thu, 20 Mar 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:25:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767629 Reopening of an assessment beyond four years is barred where the assessee has already disclosed all material facts and the issue was examined during scrutiny. The text states that the recorded reasons showed queries on promotional expenses, partial disallowance in the original assessment, and disclosure of relevant submissions and CBDT circular material. In those circumstances, the first proviso to Section 147 was not satisfied, so the reassessment amounted to a mere change of opinion and an impermissible review of a completed assessment. It also notes that the same issue had already been carried in appeal, further supporting invalidity of the notice. Case-Laws Income Tax Thu, 20 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767629