Tax Reassessment Notices Invalidated Due to Lack of Fresh Evidence Under Section 147, Original Return Had Full Disclosure

HC quashed reassessment notices and order finding them invalid under Section 147 of Income Tax Act. Notices issued after four years were without fresh material indicating escaped income. Complete disclosure was made in original return and assessment under Section 143(3). AO's attempt to revisit Section 14A disallowance constituted mere change of opinion, not valid grounds for reopening. Court emphasized that determining Section 14A disallowance was AO's responsibility during original assessment, where assessee had provided all relevant documents. Reopening failed first proviso requirements of Section 147, particularly beyond four-year limitation period. Jurisdiction could not be assumed without failure by assessee to disclose material facts. .....

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