https://www.taxtmi.com/caselaws?id=462272 The Bombay HC held that reopening of assessment for TP adjustment was invalid as it was based on change of opinion rather than failure to disclose material facts. The assessee had submitted a transfer pricing study which was accepted by the TPO, and the AO computed income based on the ALP determined by the TPO. The court emphasized that an assessee's duty extends only to full and truthful disclosure of primary facts, not drawing inferences from those facts. Since there was no allegation that the assessee was aware of third-party import prices or failed to disclose material facts, and queries during assessment proceedings were addressed, the reopening was unjustified. en-us Thu, 29 Feb 2024 00:00:00 +0530 Mon, 09 Jun 2025 16:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462272 The Bombay HC held that reopening of assessment for TP adjustment was invalid as it was based on change of opinion rather than failure to disclose material facts. The assessee had submitted a transfer pricing study which was accepted by the TPO, and the AO computed income based on the ALP determined by the TPO. The court emphasized that an assessee's duty extends only to full and truthful disclosure of primary facts, not drawing inferences from those facts. Since there was no allegation that the assessee was aware of third-party import prices or failed to disclose material facts, and queries during assessment proceedings were addressed, the reopening was unjustified. Case-Laws Income Tax Thu, 29 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462272