Allowing the petition the Court held that there was no failure on the part of the assessee to disclose fully and truly all material facts, as all relevant details and agreements had been placed on record during the original assessment proceedings. The reopening was thus held to be based on a mere change of opinion, which is impermissible. Accordingly, the reassessment proceedings were quashed and set aside. (AY. 2003-04)
Revathi Equipment Ltd. v. ACIT (2025) 306 Taxman 72 (Mad.)(HC)
S. 147 : Reassessment-After the expiry of four years-Non-compete Fee-Revenue expenditure-Change of opinion-Full disclosure of facts-Reassessment notice and order disposing the objection was quashed.[S. 37(1), 148, Art. 226]
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