https://www.taxtmi.com/caselaws?id=68935 Reassessment under Section 147(b) could not be sustained where depreciation and extra shift allowance had not been claimed by the assessee in the original assessment, because the revenue could not impose those allowances in reassessment. The reopening also rested on the same material already examined in the original assessment, so it amounted to a mere change of opinion, which is impermissible. The reassessment was therefore invalid on both merits and jurisdiction, and its cancellation was upheld in favour of the assessee. en-us Sat, 27 Feb 1982 00:00:00 +0530 Mon, 04 Apr 2011 11:16:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=68935 Reassessment under Section 147(b) could not be sustained where depreciation and extra shift allowance had not been claimed by the assessee in the original assessment, because the revenue could not impose those allowances in reassessment. The reopening also rested on the same material already examined in the original assessment, so it amounted to a mere change of opinion, which is impermissible. The reassessment was therefore invalid on both merits and jurisdiction, and its cancellation was upheld in favour of the assessee. Case-Laws Income Tax Sat, 27 Feb 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=68935