https://www.taxtmi.com/caselaws?id=788816 Reassessment under sections 147 and 148 was held invalid where the original assessment had already examined and disallowed the section 14A read with Rule 8D issue, and that treatment had been affirmed in appeal. Because reopening was initiated beyond four years, the proviso to section 147 required a recorded failure by the assessee to disclose fully and truly all material facts; none was shown. Reopening on the same material was treated as a mere change of opinion and was also barred by merger of the assessment with the appellate order. The reassessment was therefore quashed in favour of the assessee. en-us Thu, 26 Mar 2026 00:00:00 +0530 Fri, 27 Mar 2026 15:03:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788816 Reassessment under sections 147 and 148 was held invalid where the original assessment had already examined and disallowed the section 14A read with Rule 8D issue, and that treatment had been affirmed in appeal. Because reopening was initiated beyond four years, the proviso to section 147 required a recorded failure by the assessee to disclose fully and truly all material facts; none was shown. Reopening on the same material was treated as a mere change of opinion and was also barred by merger of the assessment with the appellate order. The reassessment was therefore quashed in favour of the assessee. Case-Laws Income Tax Thu, 26 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788816