Bombay HC Quashed Reopening After Four Years Due to Change of Opinion

Ceat Limited Vs ACIT (Bombay High Court) The Bombay High Court examined the validity of a notice issued under Section 148 of the Income Tax Act, 1961, for Assessment Year 2012–13, along with the order rejecting the assessee’s objections. Since the reassessment notice was issued after the expiry of four years from the end of the relevant assessment year and the original assessment had been completed under Section 143(3), the proviso to Section 147 applied. Accordingly, the Revenue was required to establish a failure on the part of the assessee to disclose fully and truly all material facts ...