https://www.taxtmi.com/caselaws?id=779438 HC held that reopening assessment under s.147 after four years was impermissible where pre-2016 law did not obligate the prescribed authority to certify allowable expenditure in Form 3CL. References to expenditure in Form 3CL were insignificant for allowing deduction and did not establish willful non-disclosure by the assessee. The assessing officer's failure to verify actual expenditure could not be used to the revenue's advantage unless attributable to the assessee. Tribunal erred in its approach; appeal allowed, impugned order set aside and question of law answered in favour of the assessee and against the revenue. en-us Fri, 19 Sep 2025 00:00:00 +0530 Mon, 06 Oct 2025 09:10:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779438 HC held that reopening assessment under s.147 after four years was impermissible where pre-2016 law did not obligate the prescribed authority to certify allowable expenditure in Form 3CL. References to expenditure in Form 3CL were insignificant for allowing deduction and did not establish willful non-disclosure by the assessee. The assessing officer's failure to verify actual expenditure could not be used to the revenue's advantage unless attributable to the assessee. Tribunal erred in its approach; appeal allowed, impugned order set aside and question of law answered in favour of the assessee and against the revenue. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779438