https://www.taxtmi.com/caselaws?id=771967 The HC held that reassessment proceedings regarding finance, sales and corporate services charges were invalid. The court found that the AO had examined all relevant facts during the original assessment and no additional material was discovered subsequently. The reassessment constituted an impermissible change of opinion rather than assessment of escaped income. Although audit observations may constitute information under Section 148, they do not expand the AO's power to review concluded assessments. The court emphasized that "escaped assessment" means income not subjected to assessment, not cases where informed assessments were made. Additionally, the notice was issued beyond the limitation period under Section 149(1), making it time-barred. The petition was allowed. en-us Wed, 21 May 2025 00:00:00 +0530 Tue, 17 Jun 2025 15:39:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771967 The HC held that reassessment proceedings regarding finance, sales and corporate services charges were invalid. The court found that the AO had examined all relevant facts during the original assessment and no additional material was discovered subsequently. The reassessment constituted an impermissible change of opinion rather than assessment of escaped income. Although audit observations may constitute information under Section 148, they do not expand the AO's power to review concluded assessments. The court emphasized that "escaped assessment" means income not subjected to assessment, not cases where informed assessments were made. Additionally, the notice was issued beyond the limitation period under Section 149(1), making it time-barred. The petition was allowed. Case-Laws Income Tax Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771967