Reassessment Beyond Four Years Invalid without New Tangible Material: Bombay HC Quashes Section 148 Notices to BPCL

The Bombay High Court invalidated reassessment proceedings initiated under Section 148 of the Income Tax Act against Bharat Petroleum Corporation Ltd. (BPCL), ruling that reassessment beyond four years is impermissible without new tangible material. The court reiterated that reopening based on change of opinion is barred by law. It emphasized adherence to statutory safeguards ensuring certainty and finality in tax assessments. The judgment protects taxpayers from arbitrary reopening and reinforces judicial oversight on misuse of reassessment powers. The decision reaffirms that tax authorities must substantiate fresh evidence of income escapement before invoking extended limitation periods under Section 147/148.