https://www.taxtmi.com/caselaws?id=774908 The HC quashed the reassessment proceedings initiated under Section 148, ruling that the AO's reopening was based on a mere change of opinion rather than tangible material indicating income escapement. The assessee had fully disclosed all primary facts including interest payments of Rs. 56,61,461/- in the original return and provided additional particulars during assessment proceedings. The court held that once all primary facts are disclosed, the assessee's duty is complete and it's for the AO to draw appropriate inferences. Since the same issue was considered during original assessment proceedings, the reopening constituted an impermissible change of opinion without valid reasons to believe income had escaped assessment. en-us Thu, 10 Jul 2025 00:00:00 +0530 Tue, 14 Jul 2026 16:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774908 The HC quashed the reassessment proceedings initiated under Section 148, ruling that the AO's reopening was based on a mere change of opinion rather than tangible material indicating income escapement. The assessee had fully disclosed all primary facts including interest payments of Rs. 56,61,461/- in the original return and provided additional particulars during assessment proceedings. The court held that once all primary facts are disclosed, the assessee's duty is complete and it's for the AO to draw appropriate inferences. Since the same issue was considered during original assessment proceedings, the reopening constituted an impermissible change of opinion without valid reasons to believe income had escaped assessment. Case-Laws Income Tax Thu, 10 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774908