Corporate TaxArticle·19 March 2026
Reopening without Foundation
By J the App
Executive Summary
This case examines whether reassessment proceedings can be initiated after four years in the absence of failure to disclose material facts.
The Court held that a bald allegation of non-disclosure is insufficient, and reopening based on reinterpretation of existing material amounts to a change of opinion.
Consequently, the reassessment notices were quashed.
The dispute arose in Assistant Commissioner of Income Tax v. Bharat Petroleum Corporation Ltd., where reassessment notices issued under Sections 147 and 148 o...
Read the full article in the app
This is a premium article. Download J the App to read the complete content.