2025 (2) TMI 198 - SCH - Income Tax

Validity of reopening of assessment - notice issued after expiry of four years - change of opinion - applicability of section 73 - HC 2024 (3) TMI 40 - BOMBAY HIGH COURT reasons recorded to believe that there is escapement of income from assessment does not even make an allegation that there was failure to truly and fully disclose material fact. reopening of assessment is merely based on the basis of change of opinion as applicability of Section 73 of the Act was a subject of consideration during the assessment proceedings HELD THAT - We do not find any good ground and reason to interfere with the impugned judgment and hence the special leave petition is dismissed.

Summary

In the Supreme Court judgment, presided over by Hon'ble Chief Justice Sanjiv Khanna and Hon'ble Mr. Justice Sanjay Kumar, the Court addressed a special leave petition. The Court, after hearing the counsel, decided to condone the delay but found no substantial grounds to interfere with the impugned judgment. Consequently, the special leave petition was dismissed. Additionally, any pending applications related to the case were ordered to stand disposed of.