https://www.taxtmi.com/caselaws?id=462552 Gujarat HC allowed the petitioner's appeal against reopening of assessment beyond four years. The AO issued notice for capital gains on conversion of company to LLP, claiming petitioner ineligible for exemption under section 47(xiiib)(e) due to turnover exceeding Rs. 60 lakh. HC held no failure to disclose material facts occurred, and AO failed to consider that conversion involved no change in shareholding percentage (1.12% remained same). The notice was based on mere change of opinion without tangible material, constituting impermissible review rather than valid reassessment. en-us Tue, 17 Jun 2025 00:00:00 +0530 Mon, 07 Jul 2025 17:53:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462552 Gujarat HC allowed the petitioner's appeal against reopening of assessment beyond four years. The AO issued notice for capital gains on conversion of company to LLP, claiming petitioner ineligible for exemption under section 47(xiiib)(e) due to turnover exceeding Rs. 60 lakh. HC held no failure to disclose material facts occurred, and AO failed to consider that conversion involved no change in shareholding percentage (1.12% remained same). The notice was based on mere change of opinion without tangible material, constituting impermissible review rather than valid reassessment. Case-Laws Income Tax Tue, 17 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462552