https://www.taxtmi.com/caselaws?id=785293 Reopening of assessment raised whether an interest-free loan constituted a deemed dividend and whether extended limitation could be invoked for nondisclosure; the court found audited books and balance-sheet notes disclosed the primary fact of the loan, negating any failure to disclose material facts, and held the notice invoking extended limitation was without jurisdiction. The legality of reassessment on mere change of opinion was addressed by reference to precedent, with the conclusion that subjecting the taxpayer to a second reassessment on the same transaction was arbitrary and violated constitutional protections; consequently writ relief was allowed. en-us Mon, 19 Jan 2026 00:00:00 +0530 Wed, 21 Jan 2026 08:41:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785293 Reopening of assessment raised whether an interest-free loan constituted a deemed dividend and whether extended limitation could be invoked for nondisclosure; the court found audited books and balance-sheet notes disclosed the primary fact of the loan, negating any failure to disclose material facts, and held the notice invoking extended limitation was without jurisdiction. The legality of reassessment on mere change of opinion was addressed by reference to precedent, with the conclusion that subjecting the taxpayer to a second reassessment on the same transaction was arbitrary and violated constitutional protections; consequently writ relief was allowed. Case-Laws Income Tax Mon, 19 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785293