(1) CIT v. Premier Mills
296 ITR 157High Court2008#9649 most cited
What is (1) CIT v. Premier Mills authority for?
Reopening an assessment under section 148 beyond four years from the relevant assessment year, following an assessment under section 143(3), is only valid if there's a proven failure by the assessee to disclose all material facts. The reassessment cannot be sustained if material facts were available during the original assessment or if it's based on a mere change of opinion.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2015 to 2026.
Also referred to as
CIT v. Premier Mills · section 148 · section 143(3) · reopening assessment · beyond four years · failure to disclose material facts · change of opinion · original assessment
