https://www.taxtmi.com/caselaws?id=770558 Delhi HC quashed reassessment u/s 147. Petitioner had made full and true disclosure during original assessment proceedings regarding remittances to SMC, TDS, and capital gains. AO was aware of all relevant facts but chose not to make additions initially. Reopening was invalid as AO merely relied on ACIT communication without independent application of mind. No fresh material discovered in subsequent AY that rendered original assessment information false or misleading. Action constituted impermissible change of opinion rather than valid reassessment based on reason to believe. en-us Fri, 21 Feb 2025 00:00:00 +0530 Mon, 12 May 2025 15:53:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770558 Delhi HC quashed reassessment u/s 147. Petitioner had made full and true disclosure during original assessment proceedings regarding remittances to SMC, TDS, and capital gains. AO was aware of all relevant facts but chose not to make additions initially. Reopening was invalid as AO merely relied on ACIT communication without independent application of mind. No fresh material discovered in subsequent AY that rendered original assessment information false or misleading. Action constituted impermissible change of opinion rather than valid reassessment based on reason to believe. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770558