Reassessment After 4 Years With Same Set of Facts Which Already Available During Original Assessment Legally Bad: ITAT

The ITAT has ruled that a reassessment after four years is "legally bad" if it's based on the "same set of facts that were already available during the original assessment." The tribunal emphasized that the tax authorities cannot reopen a case based on a mere change of opinion. This ruling provides crucial protection to taxpayers by ensuring that once an assessment is completed, it should not be revisited without a valid reason, such as new and incriminating material. This decision promotes finality in tax matters.