https://www.taxtmi.com/caselaws?id=469419 Reopening after a completed scrutiny assessment under Section 143(3) was impermissible where four years had elapsed and the recorded reasons did not show any failure by the assessee to fully and truly disclose material facts. The HC noted that the return, scrutiny assessment, and long-term capital gains were already before the Assessing Officer, so the first proviso to Section 147 was not satisfied. It also held that reopening on the same material, without fresh tangible information, amounted to a mere change of opinion. The notice under Section 148, the objections order, and the reassessment proceedings were quashed in favour of the assessee. en-us Fri, 24 Jan 2025 00:00:00 +0530 Tue, 16 Jun 2026 21:37:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469419 Reopening after a completed scrutiny assessment under Section 143(3) was impermissible where four years had elapsed and the recorded reasons did not show any failure by the assessee to fully and truly disclose material facts. The HC noted that the return, scrutiny assessment, and long-term capital gains were already before the Assessing Officer, so the first proviso to Section 147 was not satisfied. It also held that reopening on the same material, without fresh tangible information, amounted to a mere change of opinion. The notice under Section 148, the objections order, and the reassessment proceedings were quashed in favour of the assessee. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469419