https://www.taxtmi.com/caselaws?id=461676 ITAT Raipur upheld CIT(Appeals) order quashing reassessment proceedings against assessee company for AY 2012-13. While tribunal found AO had valid reasons to reopen assessment based on information about bogus purchase bills and share capital transactions (not mere change of opinion or suspicion), the reassessment was invalid due to two fatal defects: reopening occurred beyond four years without establishing assessee's failure to disclose material facts as required under Section 147 first proviso, and AO proceeded with assessment without disposing of assessee's objections to reopening validity, violating Supreme Court mandate in GKN Driveshafts case. Revenue's appeal partially allowed. en-us Wed, 29 May 2024 00:00:00 +0530 Sat, 19 Apr 2025 13:47:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461676 ITAT Raipur upheld CIT(Appeals) order quashing reassessment proceedings against assessee company for AY 2012-13. While tribunal found AO had valid reasons to reopen assessment based on information about bogus purchase bills and share capital transactions (not mere change of opinion or suspicion), the reassessment was invalid due to two fatal defects: reopening occurred beyond four years without establishing assessee's failure to disclose material facts as required under Section 147 first proviso, and AO proceeded with assessment without disposing of assessee's objections to reopening validity, violating Supreme Court mandate in GKN Driveshafts case. Revenue's appeal partially allowed. Case-Laws Income Tax Wed, 29 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461676