https://www.taxtmi.com/caselaws?id=207651 Reopening of assessment under section 147 was found invalid where the Assessing Officer relied on the same facts already examined in earlier section 263 proceedings and no fresh material had come to light after the original processing. The Tribunal held that the reassessment notice merely repeated the earlier points, so the Assessing Officer lacked an independent basis to form a belief that income had escaped assessment. In the absence of new material, the attempt amounted to a mere change of opinion. The reopening was therefore held bad in law and without jurisdiction. en-us Tue, 16 Feb 2010 00:00:00 +0530 Tue, 20 Dec 2011 09:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207651 Reopening of assessment under section 147 was found invalid where the Assessing Officer relied on the same facts already examined in earlier section 263 proceedings and no fresh material had come to light after the original processing. The Tribunal held that the reassessment notice merely repeated the earlier points, so the Assessing Officer lacked an independent basis to form a belief that income had escaped assessment. In the absence of new material, the attempt amounted to a mere change of opinion. The reopening was therefore held bad in law and without jurisdiction. Case-Laws Income Tax Tue, 16 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207651