https://www.taxtmi.com/caselaws?id=771846 ITAT Delhi allowed the assessee's appeal, quashing the reassessment notice issued under section 148 beyond the four-year limitation period. The tribunal held that the AO wrongly assumed jurisdiction under section 147/148 as the alleged escapement of income was based on documents already available during the original assessment under section 153A. The AO failed to establish that income escaped due to the assessee's failure to fully disclose material facts. The tribunal ruled this was merely a change of opinion by the AO, which cannot justify reopening beyond the limitation period, making the reassessment notice legally invalid. en-us Wed, 02 Apr 2025 00:00:00 +0530 Sat, 31 May 2025 08:47:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771846 ITAT Delhi allowed the assessee's appeal, quashing the reassessment notice issued under section 148 beyond the four-year limitation period. The tribunal held that the AO wrongly assumed jurisdiction under section 147/148 as the alleged escapement of income was based on documents already available during the original assessment under section 153A. The AO failed to establish that income escaped due to the assessee's failure to fully disclose material facts. The tribunal ruled this was merely a change of opinion by the AO, which cannot justify reopening beyond the limitation period, making the reassessment notice legally invalid. Case-Laws Income Tax Wed, 02 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771846