https://www.taxtmi.com/highlights?id=93105 The HC held that reopening under Section 147 is unsustainable where the assessee had divulged full and true primary facts in the return; the impugned reassessment lacked statutory foundation and therefore contravened Section 147. A mere change of opinion by the AO cannot constitute a valid reason to reopen assessment. Issuance of a second notice while an earlier notice subsisted was declared invalid, rendering consequent proceedings a nullity. In view of these conclusions the writ petition was allowed and the reassessment proceedings and consequential orders were quashed. en-us Mon, 06 Oct 2025 09:10:50 +0530 Mon, 06 Oct 2025 09:10:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93105 The HC held that reopening under Section 147 is unsustainable where the assessee had divulged full and true primary facts in the return; the impugned reassessment lacked statutory foundation and therefore contravened Section 147. A mere change of opinion by the AO cannot constitute a valid reason to reopen assessment. Issuance of a second notice while an earlier notice subsisted was declared invalid, rendering consequent proceedings a nullity. In view of these conclusions the writ petition was allowed and the reassessment proceedings and consequential orders were quashed. Highlights Income Tax Mon, 06 Oct 2025 09:10:50 +0530 https://www.taxtmi.com/highlights?id=93105