https://www.taxtmi.com/caselaws?id=774190 Bombay HC quashed reassessment notices u/s 147 for AY 2013-14 and 2014-15, holding that AO failed to establish non-disclosure of material facts by petitioner. Court found that petitioner had fully disclosed dividend income from BPCL Trust and section 32AC deduction details during original scrutiny proceedings. The reassessment was based merely on change of opinion regarding exemption eligibility rather than discovery of new material facts. Since proceedings were initiated beyond four years without proper justification and original assessments were completed u/s 143(3) with full disclosure, the notices were deemed bad in law and unsustainable. en-us Thu, 03 Jul 2025 00:00:00 +0530 Fri, 04 Jul 2025 10:19:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774190 Bombay HC quashed reassessment notices u/s 147 for AY 2013-14 and 2014-15, holding that AO failed to establish non-disclosure of material facts by petitioner. Court found that petitioner had fully disclosed dividend income from BPCL Trust and section 32AC deduction details during original scrutiny proceedings. The reassessment was based merely on change of opinion regarding exemption eligibility rather than discovery of new material facts. Since proceedings were initiated beyond four years without proper justification and original assessments were completed u/s 143(3) with full disclosure, the notices were deemed bad in law and unsustainable. Case-Laws Income Tax Thu, 03 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774190