Reopening of Assessment after 4 years only if some new Tangible material

Arun Munshaw HUF Vs ITO (Gujarat High Court)

Thus, having regard to the position of law and the materials emerging from the record of the case, it cannot be said that there was no full and true disclosure at the end of the assessee of the material facts. In such circumstances, it could be said that there was no tangible material with the Assessing Officer for the purpose of reopening the assessment except the change of opinion that the deductions could not have been claimed and allowed under Sections 53(b) and 54(1) (i) of the Act. The conveyance deed;

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