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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...

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