CMI FPE Ltd. v. UOI (2019) 263 Taxman 433 (Bom.)(HC)

S. 147 : Reassessment-After the expiry of four years- Prior period expenses – Disclosed all material facts necessary for assessment-Initiation of reassessment proceedings merely on basis of change of opinion is not justified.[S. 37(1), 148]

Allowing the petition the Court held that the assessee had duly disclosed all material facts necessary for assessment in respect of prior period expenses. Accordingly in view of proviso to S.147, initiation of reassessment proceedings merely on basis of change of opinion is held to be not justified. (AY. 2011-12)