Delhi HC Quashes Reassessment for Change of Opinion, No Disclosure Failure by Assessee

Allied Strips Limited Vs ACIT (Delhi High Court) The Delhi High Court has set aside a notice issued by the Assistant Commissioner of Income Tax (ACIT) seeking to re-open the tax assessment of Allied Strips Limited for the Assessment Year 2007-08. The court, in its judgment, ruled that the reassessment proceedings, initiated more than four years after the relevant assessment year, were invalid on two primary grounds: they were based on a mere change of opinion by the tax authorities, and the mandatory pre-condition of alleging the assessee’s failure to fully and truly disclose material fa...