https://www.taxtmi.com/caselaws?id=782760 HC quashed the reassessment proceedings initiated u/s 147 on the ground that the AO's "reasons to believe" were based solely on a change of opinion. The assessee had made full and true disclosure of all primary facts, including detailed documentation of purchases from a named supplier, and the original assessment was completed after thorough scrutiny. In absence of any new tangible material or failure to disclose, the subsequent allegation of ingenuine transactions and colourable device was held unsustainable. Reopening was declared invalid and relief granted to the assessee. en-us Tue, 25 Nov 2025 00:00:00 +0530 Wed, 03 Dec 2025 08:57:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782760 HC quashed the reassessment proceedings initiated u/s 147 on the ground that the AO's "reasons to believe" were based solely on a change of opinion. The assessee had made full and true disclosure of all primary facts, including detailed documentation of purchases from a named supplier, and the original assessment was completed after thorough scrutiny. In absence of any new tangible material or failure to disclose, the subsequent allegation of ingenuine transactions and colourable device was held unsustainable. Reopening was declared invalid and relief granted to the assessee. Case-Laws Income Tax Tue, 25 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782760