https://www.taxtmi.com/caselaws?id=767622 The Bombay HC quashed a reassessment notice u/s 147 where the revenue sought to disallow sample expenses to doctors as sales promotion. The court held that since these expenses were not disallowed during original assessment proceedings, there was no failure by the assessee to disclose material facts. The assessing officer's failure to disallow expenses initially cannot justify reopening after four years. The revenue failed to rebut the assessee's objection regarding full disclosure, effectively accepting no failure occurred. The reassessment notice was quashed for non-fulfillment of conditions under the first proviso to section 147. en-us Mon, 10 Mar 2025 00:00:00 +0530 Fri, 20 Feb 2026 17:22:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767622 The Bombay HC quashed a reassessment notice u/s 147 where the revenue sought to disallow sample expenses to doctors as sales promotion. The court held that since these expenses were not disallowed during original assessment proceedings, there was no failure by the assessee to disclose material facts. The assessing officer's failure to disallow expenses initially cannot justify reopening after four years. The revenue failed to rebut the assessee's objection regarding full disclosure, effectively accepting no failure occurred. The reassessment notice was quashed for non-fulfillment of conditions under the first proviso to section 147. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767622