https://www.taxtmi.com/caselaws?id=209043 Reassessment under section 147 was treated as impermissible where the original scrutiny assessment under section 143(3) had already examined the same expenditure claim and no fresh tangible material had emerged. The majority view was that reopening on the basis of the existing record amounted to a mere change of opinion, which cannot justify reassessment unless new material has a live link to the belief that income escaped assessment. On that reasoning, the reopening was held invalid and void ab initio. A dissenting view considered that relevant aspects had been overlooked in the original assessment and that the recorded reasons were supported by material, so the reopening was valid. en-us Fri, 07 May 2010 00:00:00 +0530 Sat, 12 May 2012 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=209043 Reassessment under section 147 was treated as impermissible where the original scrutiny assessment under section 143(3) had already examined the same expenditure claim and no fresh tangible material had emerged. The majority view was that reopening on the basis of the existing record amounted to a mere change of opinion, which cannot justify reassessment unless new material has a live link to the belief that income escaped assessment. On that reasoning, the reopening was held invalid and void ab initio. A dissenting view considered that relevant aspects had been overlooked in the original assessment and that the recorded reasons were supported by material, so the reopening was valid. Case-Laws Income Tax Fri, 07 May 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=209043