AO cannot reopen an assessment even within a period of 4 years merely on the basis of a change of opinion

Glaxosmithkline Pharmaceuticals Ltd. Vs ACIT/DCIT (Bombay High Court) Admittedly, this is a case where the notice under Section 148 of the Act has been issued after the expiry of 4 years from the end of the relevant assessment year and assessment under Section 143(3) of the Act has also been completed. Hence, proviso to Section 147 of the Act shall apply. Respondents have to show that there was failure on the part of petitioner to truly and fully disclose material facts relevant for the assessment. We have considered the reasons recorded for reopening the assessment and we have no doubt in con...