https://www.taxtmi.com/caselaws?id=773092 ITAT Ahmedabad quashed reassessment proceedings initiated beyond four years based on re-examination of existing records without new evidence. The AO attempted to reopen assessment regarding agricultural land sale despite assessee having disclosed all details in original proceedings under section 143(3) with supporting documents. The tribunal held that mere change of opinion on same facts cannot justify reopening beyond statutory period. Since assessee made true and fair disclosure in original assessment and AO had verified all submissions before passing initial order, the notice under section 148 was held bad in law. Appeal allowed. en-us Wed, 30 Apr 2025 00:00:00 +0530 Wed, 18 Jun 2025 09:04:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773092 ITAT Ahmedabad quashed reassessment proceedings initiated beyond four years based on re-examination of existing records without new evidence. The AO attempted to reopen assessment regarding agricultural land sale despite assessee having disclosed all details in original proceedings under section 143(3) with supporting documents. The tribunal held that mere change of opinion on same facts cannot justify reopening beyond statutory period. Since assessee made true and fair disclosure in original assessment and AO had verified all submissions before passing initial order, the notice under section 148 was held bad in law. Appeal allowed. Case-Laws Income Tax Wed, 30 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773092