https://www.taxtmi.com/caselaws?id=470596 Reassessment initiated after four years is examined against the proviso to section 147, requiring recorded reasons to allege failure to make a full and true disclosure of material facts. Where transactions were examined in the original assessment and reopening relies on the same material, it is characterised as an impermissible change of opinion. The notes also address section 14A, stating that rule 8D disallowance requires the Assessing Officer's recorded satisfaction on the correctness of the taxpayer's claim and a basis linking expenditure to exempt income. Business-expense disallowance under section 37 is unsupported where books and details are furnished without identified defects. en-us Fri, 21 Mar 2025 00:00:00 +0530 Fri, 31 Jul 2026 19:03:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470596 Reassessment initiated after four years is examined against the proviso to section 147, requiring recorded reasons to allege failure to make a full and true disclosure of material facts. Where transactions were examined in the original assessment and reopening relies on the same material, it is characterised as an impermissible change of opinion. The notes also address section 14A, stating that rule 8D disallowance requires the Assessing Officer's recorded satisfaction on the correctness of the taxpayer's claim and a basis linking expenditure to exempt income. Business-expense disallowance under section 37 is unsupported where books and details are furnished without identified defects. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470596