Income Tax Reassessment Quashed: Change of Opinion Illegal

Saravana Stocks Investments Pvt. Ltd. Vs DCIT (Madras High Court)

Madras High Court has quashed reassessment proceedings initiated against Saravana Stocks Investments Pvt. Ltd. for the assessment year 2006-07. The court determined that the reassessment was based on a mere change of opinion by the Assessing Officer, which is impermissible after the lapse of four years from the end of the relevant assessment year, especially when there was no failure on the part of the assessee to fully and truly disclose all material facts.

The case involved the treatment of income derived fr

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