https://www.taxtmi.com/caselaws?id=780878 Reopening of assessment under section 147 in a slump sale was contested on grounds that the assessing officer lacked jurisdiction to form a reason to believe beyond four years. The administrative record showed depreciation was allowed during regular assessment based on an expert valuer's allocation of sale consideration to individual assets, with the residual treated as goodwill and depreciated at 25%. Because the valuation allocation and depreciation were accepted in assessment, the basis for reassessment was held insufficient and the Special Leave Petition against the High Court order was dismissed, leaving the reopening denied. en-us Mon, 13 Oct 2025 00:00:00 +0530 Tue, 10 Feb 2026 11:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780878 Reopening of assessment under section 147 in a slump sale was contested on grounds that the assessing officer lacked jurisdiction to form a reason to believe beyond four years. The administrative record showed depreciation was allowed during regular assessment based on an expert valuer's allocation of sale consideration to individual assets, with the residual treated as goodwill and depreciated at 25%. Because the valuation allocation and depreciation were accepted in assessment, the basis for reassessment was held insufficient and the Special Leave Petition against the High Court order was dismissed, leaving the reopening denied. Case-Laws Income Tax Mon, 13 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780878