https://www.taxtmi.com/caselaws?id=767629 The Bombay HC quashed reassessment proceedings under Section 147 initiated after four years. The court held that the precondition of failure to disclose material facts was not satisfied, as the assessing officer had already examined promotional expenses during original assessment and allowed two-thirds of the expenditure. The reassessment was deemed impermissible as it constituted a change of opinion rather than valid reopening. Additionally, since the issue was already decided by CIT(A) before initiation of proceedings, the reassessment lacked jurisdiction under the third proviso to Section 147. en-us Thu, 20 Mar 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:25:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767629 The Bombay HC quashed reassessment proceedings under Section 147 initiated after four years. The court held that the precondition of failure to disclose material facts was not satisfied, as the assessing officer had already examined promotional expenses during original assessment and allowed two-thirds of the expenditure. The reassessment was deemed impermissible as it constituted a change of opinion rather than valid reopening. Additionally, since the issue was already decided by CIT(A) before initiation of proceedings, the reassessment lacked jurisdiction under the third proviso to Section 147. Case-Laws Income Tax Thu, 20 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767629