Reassessment u/s 147 void in absence of fresh tangible material with AO

ACIT Vs M/s Goldmohur Design and Apparel Park Ltd. (ITAT Mumbai) Under the new provisions of section 147, an assessment can be reopened if the Assessing Officer has ‘reason to believe’ that income chargeable to tax has escaped assessment; but if he wants to do so after a period of four years or merely on the change of opinion, he can do so only if the assessee has fallen short of his duty to disclose fully and truly all material facts necessary for his assessment. The Act places a general duty on every assessee to furnish full and true particulars along with the return of income or...