Reassessment notice was issued on 31-3-2021. In the recorded reason it was stated that amount received towards corpus fund has to be treated as income of the current year. The objection of the assessee was rejected. On writ allowing the petition the Court held  it is nothing but change of opinion which is not permissible in law and there was no failure on the part of petitioner to fully and truly disclosed any material fact. It is settled law that where a notice under Section 143 of the Act is issued after expiry of four years after relevant assessment year, such a notice can be issued only if respondents are able to effectively demonstrate that there was failure on the part of assessee to fully and truly disclosed material facts before the original Assessment order was passed. Court also observed that DCIT (E)  which indicates that decision to reopen the assessment on the basis of audit query. Notice for reassessment and order disposing the objection was quashed.  (WP No. 3045 of 2021,  dt. 8.12.21)(AY. 2013-2014)

All India Rubber Industries Association v. ACIT (Bom.)(HC)(UR)