https://www.taxtmi.com/caselaws?id=786736 Audit objections do not qualify as fresh information permitting reassessment where the assessing officer had the same documents and had considered them during the original scrutiny; reopening on that basis is an impermissible change of opinion and thus invalid, and notices issued on that basis must be set aside. Further, a notice issued beyond the four year limitation period is time barred where no failure to disclose material facts is established; such notices and consequent reassessment proceedings are quashed as beyond limitation. Operative effect: reassessment initiated on these grounds cannot be sustained and is rendered void. en-us Mon, 16 Feb 2026 00:00:00 +0530 Wed, 18 Feb 2026 08:12:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786736 Audit objections do not qualify as fresh information permitting reassessment where the assessing officer had the same documents and had considered them during the original scrutiny; reopening on that basis is an impermissible change of opinion and thus invalid, and notices issued on that basis must be set aside. Further, a notice issued beyond the four year limitation period is time barred where no failure to disclose material facts is established; such notices and consequent reassessment proceedings are quashed as beyond limitation. Operative effect: reassessment initiated on these grounds cannot be sustained and is rendered void. Case-Laws Income Tax Mon, 16 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786736