https://www.taxtmi.com/highlights?id=89520 ITAT invalidated reassessment proceedings initiated beyond four years, finding no new substantive evidence to justify reopening. The Tribunal determined that the Assessing Officer's attempt to reopen the case was merely a change of opinion on existing facts, without discovering any fresh information. The assessee had previously disclosed all relevant details during original assessment proceedings, including land sale particulars in audited financial statements. Consequently, the Tribunal quashed the notice under Section 148 and the subsequent reassessment order, thereby allowing the assessee's appeal and rendering the reopening proceedings legally unsustainable. en-us Wed, 18 Jun 2025 09:04:25 +0530 Wed, 18 Jun 2025 09:04:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=89520 ITAT invalidated reassessment proceedings initiated beyond four years, finding no new substantive evidence to justify reopening. The Tribunal determined that the Assessing Officer's attempt to reopen the case was merely a change of opinion on existing facts, without discovering any fresh information. The assessee had previously disclosed all relevant details during original assessment proceedings, including land sale particulars in audited financial statements. Consequently, the Tribunal quashed the notice under Section 148 and the subsequent reassessment order, thereby allowing the assessee's appeal and rendering the reopening proceedings legally unsustainable. Highlights Income Tax Wed, 18 Jun 2025 09:04:25 +0530 https://www.taxtmi.com/highlights?id=89520