Reopening Assessment After Four Years Invalid Without Non-Disclosure Under Sections 147 and 148 IT Act

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....The HC held that the reopening of the assessment after four years was invalid as the AO failed to establish any failure by the assessee to disclose material facts necessary for AY 2013-14. The AO's reasons merely reflected a change of opinion, which is impermissible under Sections 147 and 148 of the IT Act. The Court emphasized that reassessment jurisdiction arises only upon non-disclosure of material facts, not from mere disagreement with the original assessment. The recorded reasons must be self-explanatory, based on evidence, and cannot be supplemented later by affidavits or oral submissions. Since the AO's notice was issued without satisfying these jurisdictional requirements, the re-assessment proceedings were quashed, and the assessee's appeal was allowed.....