https://www.taxtmi.com/caselaws?id=61986 Reopening under section 147(b) was held invalid where the reassessment relied on material already on record at the original assessment. The assessment file showed that the Income-tax Officer had already examined the facts relating to installation of the freezing plant, the alleged purchase agreement, and the assessee's development rebate claim. A later reassessment based on the same material, after a fresh appreciation of its significance, amounted only to a change of opinion. That was insufficient to found jurisdiction under section 147(b), so the reassessment was annulled in favour of the assessee. en-us Fri, 31 Jul 1987 00:00:00 +0530 Mon, 17 Jan 2011 14:17:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61986 Reopening under section 147(b) was held invalid where the reassessment relied on material already on record at the original assessment. The assessment file showed that the Income-tax Officer had already examined the facts relating to installation of the freezing plant, the alleged purchase agreement, and the assessee's development rebate claim. A later reassessment based on the same material, after a fresh appreciation of its significance, amounted only to a change of opinion. That was insufficient to found jurisdiction under section 147(b), so the reassessment was annulled in favour of the assessee. Case-Laws Income Tax Fri, 31 Jul 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61986