https://www.taxtmi.com/caselaws?id=777388 ITAT BANGALORE - AT held that reassessment proceedings u/s 148 were invalid and time-barred where the AO reopened assessment after the four-year limitation period for AY 2014-15. Citing the SC principle that reassessment cannot be based on a mere change of opinion when primary facts were fully and truly disclosed, the Tribunal found the assessee had supplied required details and the AO had earlier accepted them by not rejecting explanations. Reopening thus amounted to an impermissible review; reassessment was annulled and the assessee's appeal allowed. en-us Thu, 09 Jan 2025 00:00:00 +0530 Fri, 29 Aug 2025 08:56:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777388 ITAT BANGALORE - AT held that reassessment proceedings u/s 148 were invalid and time-barred where the AO reopened assessment after the four-year limitation period for AY 2014-15. Citing the SC principle that reassessment cannot be based on a mere change of opinion when primary facts were fully and truly disclosed, the Tribunal found the assessee had supplied required details and the AO had earlier accepted them by not rejecting explanations. Reopening thus amounted to an impermissible review; reassessment was annulled and the assessee's appeal allowed. Case-Laws Income Tax Thu, 09 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777388