https://www.taxtmi.com/caselaws?id=470596 Reassessment initiated after four years is invalid where the underlying transactions were examined in the original assessments, the recorded reasons identify no fresh material, and they do not allege failure to make a full and true disclosure of material facts. Reconsidering previously examined material constitutes an impermissible change of opinion, rendering the reassessment proceedings and consequential orders void. Disallowance relating to exempt income cannot be made by applying rule 8D without the Assessing Officer recording satisfaction on the correctness of the taxpayer's claim. Business-expenditure disallowance is also unsustainable where supporting details and books were furnished, no defects were identified, and no evidentiary basis supported the adjustment. 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 invalid where the underlying transactions were examined in the original assessments, the recorded reasons identify no fresh material, and they do not allege failure to make a full and true disclosure of material facts. Reconsidering previously examined material constitutes an impermissible change of opinion, rendering the reassessment proceedings and consequential orders void. Disallowance relating to exempt income cannot be made by applying rule 8D without the Assessing Officer recording satisfaction on the correctness of the taxpayer's claim. Business-expenditure disallowance is also unsustainable where supporting details and books were furnished, no defects were identified, and no evidentiary basis supported the adjustment. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470596