https://www.taxtmi.com/caselaws?id=210435 Where block assessment proceedings were dropped because the assessee failed to produce complete accounts, bills and vouchers and did not cooperate, the Assessing Officer could validly reopen the matter under sections 147 and 148 and make a best judgment assessment under section 144 on the material gathered during search. The Court treated this as a permissible reassessment rather than an impermissible change of opinion, because there had been no merits-based determination in the earlier block proceedings. It further held that a section 260A appeal is maintainable only on a substantial question of law, and that purely factual findings and income estimation issues do not meet that threshold. en-us Thu, 15 Sep 2011 00:00:00 +0530 Fri, 10 Feb 2012 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210435 Where block assessment proceedings were dropped because the assessee failed to produce complete accounts, bills and vouchers and did not cooperate, the Assessing Officer could validly reopen the matter under sections 147 and 148 and make a best judgment assessment under section 144 on the material gathered during search. The Court treated this as a permissible reassessment rather than an impermissible change of opinion, because there had been no merits-based determination in the earlier block proceedings. It further held that a section 260A appeal is maintainable only on a substantial question of law, and that purely factual findings and income estimation issues do not meet that threshold. Case-Laws Income Tax Thu, 15 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210435