#Section 148
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No reopening of Assessment after 4 Year if no failure of Assessee in disclosing relevant facts

AO cannot take second view on same set of facts treating earlier view as erroneous

No reopening of Assessment for mere client code modification

Order passed without disposing objections against section 148 notice was invalid

Re-opening of concluded assessment not valid if no failure on the part of petitioner to disclose fully & truly all material facts

Reopening not justified when all aspects were examined in original assessment proceedings

Issue examined under original assessment proceeding cannot be reexamined

Reopening of Assessment not allowed to Form Change of Opinion

Reopening without bringing out any fresh material on record is unjustified

Reassessment not valid if No notice under section 143(2) issued to assessee

AO cannot reopen a case to re-examine issue examined during original assessment

Assessment cannot be reopened u/s 147 Based on Material Assessed by AO in Original Assessment

Reopening of Assessment for mere Difference in Valuation Report Not Justified

Reopening to assess Income under different head due to change of opinion is invalid
Explore the latest Section 148 updates on TaxGuru, including relevant Income-tax Act provisions, rules, notifications, circulars, judicial decisions and compliance guidance. The coverage highlights important tax positions, procedural requirements, assessments, deductions, penalties and litigation developments to help taxpayers and professionals understand the practical implications of changes in income-tax law.
