https://www.taxtmi.com/caselaws?id=773184 The HC upheld CIT(A)'s dismissal of Revenue's appeal challenging reopening of assessment for AY 2008-09 under section 147 read with section 153C. The court held reopening beyond four years was invalid as AO failed to establish assessee's failure to disclose material facts fully and truly, as mandated by section 147 proviso. Reasons recorded were based on SFIO information regarding ABW group's alleged modus operandi rather than AO's independent belief about specific assessee conduct. The court ruled this constituted impermissible roving enquiry, emphasizing that group-wide allegations cannot justify individual reopening without specific material against the assessee. Reopening was declared bad in law. en-us Tue, 29 Apr 2025 00:00:00 +0530 Thu, 19 Jun 2025 08:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773184 The HC upheld CIT(A)'s dismissal of Revenue's appeal challenging reopening of assessment for AY 2008-09 under section 147 read with section 153C. The court held reopening beyond four years was invalid as AO failed to establish assessee's failure to disclose material facts fully and truly, as mandated by section 147 proviso. Reasons recorded were based on SFIO information regarding ABW group's alleged modus operandi rather than AO's independent belief about specific assessee conduct. The court ruled this constituted impermissible roving enquiry, emphasizing that group-wide allegations cannot justify individual reopening without specific material against the assessee. Reopening was declared bad in law. Case-Laws Income Tax Tue, 29 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773184