https://www.taxtmi.com/caselaws?id=774538 Bombay HC quashed reassessment proceedings initiated after 4 years where AO sought to disallow excess accumulation under Section 11(2) of Income Tax Act. Court held that during original scrutiny, the trust had fully disclosed its claim for deemed application/accumulation of Rs. 32 crores, which AO had accepted before passing nil assessment order. The reopening notice was based on change of opinion rather than non-disclosure of material facts, making it jurisdictionally invalid. Court emphasized that reassessment requires failure to disclose material facts, not mere review of earlier conclusions. Petition allowed. en-us Tue, 24 Jun 2025 00:00:00 +0530 Thu, 10 Jul 2025 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774538 Bombay HC quashed reassessment proceedings initiated after 4 years where AO sought to disallow excess accumulation under Section 11(2) of Income Tax Act. Court held that during original scrutiny, the trust had fully disclosed its claim for deemed application/accumulation of Rs. 32 crores, which AO had accepted before passing nil assessment order. The reopening notice was based on change of opinion rather than non-disclosure of material facts, making it jurisdictionally invalid. Court emphasized that reassessment requires failure to disclose material facts, not mere review of earlier conclusions. Petition allowed. Case-Laws Income Tax Tue, 24 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774538