https://www.taxtmi.com/caselaws?id=76213 Reopening assessments under sections 147/148 requires tangible material showing escaped income; a mere change of opinion is insufficient, and absence of such material renders reopening unsustainable. A subsequent legislative amendment cannot be relied upon where it was not in force on the date the power to reopen was exercised; reasons for reopening must be confined to those present to the officer at that time. The Assessing Officers view on computation of book profits under section 115JB was at least a probable view supported by precedent, so reopening on that basis was unwarranted and invalidated. en-us Thu, 04 Mar 2010 00:00:00 +0530 Wed, 28 Jan 2026 12:25:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=76213 Reopening assessments under sections 147/148 requires tangible material showing escaped income; a mere change of opinion is insufficient, and absence of such material renders reopening unsustainable. A subsequent legislative amendment cannot be relied upon where it was not in force on the date the power to reopen was exercised; reasons for reopening must be confined to those present to the officer at that time. The Assessing Officers view on computation of book profits under section 115JB was at least a probable view supported by precedent, so reopening on that basis was unwarranted and invalidated. Case-Laws Income Tax Thu, 04 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=76213