No Reopening of Income Tax Assessment w/out Failure to Disclose Fully and Truly all Material Facts Necessary: Bombay HC

The Bombay High Court has issued a ruling that restricts the reopening of income tax assessments, stating that an assessment cannot be reopened unless there is demonstrable material non-disclosure by the taxpayer. The court emphasized that the tax authorities cannot reassess an individual's or entity's income merely on a change of opinion or re-evaluation of already disclosed facts. Instead, reopening is permissible only if the taxpayer failed to disclose essential facts relevant to the assessment during the original scrutiny. This decision protects taxpayers from arbitrary reassessments and ensures stability in concluded tax proceedings.