https://www.taxtmi.com/caselaws?id=202562 A completed scrutiny assessment under section 143(3) cannot be reopened under sections 147 and 148 merely because the Assessing Officer later prefers a different view on the same material already disclosed, including the sale deed and capital gains particulars. Once the assessee has fully and truly placed the relevant facts before the Assessing Officer, a presumption arises that the original assessment was made on application of mind. The absence of a detailed discussion in the assessment order does not, by itself, justify reassessment. Reopening based only on a change of opinion is invalid, so the notice under section 148 was quashed and the reassessment proceedings could not stand. en-us Wed, 08 Jul 2009 00:00:00 +0530 Sat, 18 Aug 2012 10:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=202562 A completed scrutiny assessment under section 143(3) cannot be reopened under sections 147 and 148 merely because the Assessing Officer later prefers a different view on the same material already disclosed, including the sale deed and capital gains particulars. Once the assessee has fully and truly placed the relevant facts before the Assessing Officer, a presumption arises that the original assessment was made on application of mind. The absence of a detailed discussion in the assessment order does not, by itself, justify reassessment. Reopening based only on a change of opinion is invalid, so the notice under section 148 was quashed and the reassessment proceedings could not stand. Case-Laws Income Tax Wed, 08 Jul 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=202562