https://www.taxtmi.com/caselaws?id=201655 HC held that reassessment proceedings initiated under section 147 for AYs 1997-98 and 1998-99 were invalid, as the only basis for reopening was an alleged suppression of sales inferred from comparing the average price of closing stock with disclosed sales. The reasons recorded showed that the AO relied solely on the same assessment records originally filed by the assessee, indicating a mere change of opinion rather than any new tangible material. Such change of opinion cannot justify reassessment. Consequently, the notices issued under section 148 were quashed. en-us Fri, 11 Dec 2009 00:00:00 +0530 Fri, 28 Nov 2025 15:16:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=201655 HC held that reassessment proceedings initiated under section 147 for AYs 1997-98 and 1998-99 were invalid, as the only basis for reopening was an alleged suppression of sales inferred from comparing the average price of closing stock with disclosed sales. The reasons recorded showed that the AO relied solely on the same assessment records originally filed by the assessee, indicating a mere change of opinion rather than any new tangible material. Such change of opinion cannot justify reassessment. Consequently, the notices issued under section 148 were quashed. Case-Laws Income Tax Fri, 11 Dec 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=201655