https://www.taxtmi.com/caselaws?id=778871 ITAT held the Section 147 reopening for AY 2013-14 was issued within the four-year period so the proviso requiring failure to disclose material facts did not apply. However, the reopening was quashed because the reasons recorded lacked any reference to source material or information constituting "reasons to believe," and the AO's treatment amounted to an assessment error amendable by revision rather than reassessment. The tribunal also found no valid change-of-opinion basis and rejected reliance on consistency with the next AY; consequently the reassessment proceedings were held unsustainable. en-us Tue, 21 Jan 2025 00:00:00 +0530 Mon, 22 Sep 2025 12:40:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778871 ITAT held the Section 147 reopening for AY 2013-14 was issued within the four-year period so the proviso requiring failure to disclose material facts did not apply. However, the reopening was quashed because the reasons recorded lacked any reference to source material or information constituting "reasons to believe," and the AO's treatment amounted to an assessment error amendable by revision rather than reassessment. The tribunal also found no valid change-of-opinion basis and rejected reliance on consistency with the next AY; consequently the reassessment proceedings were held unsustainable. Case-Laws Income Tax Tue, 21 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778871