https://www.taxtmi.com/caselaws?id=769221 Gujarat HC quashed reassessment notice u/s 148 issued after four years where petitioner had fully disclosed material facts and original assessment was completed under scrutiny u/s 143(3). Court held that AO cannot reopen assessment when all facts were disclosed during scrutiny assessment. The attempt to reconsider whether interest cost u/s 37(1) constituted capital or revenue expenditure was deemed mere change of opinion, which is impermissible under Kelvinator precedent. Notice and consequential proceedings were set aside in favor of assessee. en-us Tue, 08 Apr 2025 00:00:00 +0530 Tue, 22 Apr 2025 08:31:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769221 Gujarat HC quashed reassessment notice u/s 148 issued after four years where petitioner had fully disclosed material facts and original assessment was completed under scrutiny u/s 143(3). Court held that AO cannot reopen assessment when all facts were disclosed during scrutiny assessment. The attempt to reconsider whether interest cost u/s 37(1) constituted capital or revenue expenditure was deemed mere change of opinion, which is impermissible under Kelvinator precedent. Notice and consequential proceedings were set aside in favor of assessee. Case-Laws Income Tax Tue, 08 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769221