No reassessment beyond four years merely on basis of change of opinion

Textron India Private Ltd. Vs DCIT (ITAT Bangalore) Conclusion: Reassessment was bad in law beyond four years when the tax payer had disclosed the facts at the time of original assessment proceedings and the AO did not draw any adverse inference regarding the same. Held: In the present case, there was regular original assessment that was completed u/s. 143(3) r.w.s. 144C on 24.1.2012. During the course of original assessment proceedings, deduction u/s. 10A was considered by AO and granted accordingly. In the reasons recorded, there was no allegation by the AO that there was any failure on the...