https://www.taxtmi.com/caselaws?id=767900 Reopening of assessment under section 147 beyond four years was held invalid where the assessee had made full and complete disclosures and the original assessment was made after considering those disclosures. The revenue admitted reassessment was prompted by an audit objection but did not communicate those reasons in the reopening notice; relevant precedents favouring the assessee were already available. The court treated the attempt as a prohibited change of opinion, not a permissible reassessment or failure to disclose, and ruled in favour of the assessee. en-us Mon, 24 Mar 2025 00:00:00 +0530 Mon, 09 Feb 2026 14:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767900 Reopening of assessment under section 147 beyond four years was held invalid where the assessee had made full and complete disclosures and the original assessment was made after considering those disclosures. The revenue admitted reassessment was prompted by an audit objection but did not communicate those reasons in the reopening notice; relevant precedents favouring the assessee were already available. The court treated the attempt as a prohibited change of opinion, not a permissible reassessment or failure to disclose, and ruled in favour of the assessee. Case-Laws Income Tax Mon, 24 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767900