https://www.taxtmi.com/caselaws?id=211526 Section 147 permits reassessment where income has escaped assessment even after a block assessment under Chapter XIV-B, subject to the statutory safeguards; the reopening was therefore valid in favour of the Revenue. Reassessment is not barred by change of opinion unless the Assessing Officer had actually formed a view on the same issue in the original proceedings, and the record here showed omission or oversight rather than any concluded opinion. On that basis, the reopening was not invalid as a mere change of opinion. The Tribunal's order was set aside, the Revenue's appeals succeeded, and the matter was remanded for decision on the remaining merits, including the deemed dividend question. en-us Thu, 06 Jan 2011 00:00:00 +0530 Mon, 22 Sep 2025 16:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211526 Section 147 permits reassessment where income has escaped assessment even after a block assessment under Chapter XIV-B, subject to the statutory safeguards; the reopening was therefore valid in favour of the Revenue. Reassessment is not barred by change of opinion unless the Assessing Officer had actually formed a view on the same issue in the original proceedings, and the record here showed omission or oversight rather than any concluded opinion. On that basis, the reopening was not invalid as a mere change of opinion. The Tribunal's order was set aside, the Revenue's appeals succeeded, and the matter was remanded for decision on the remaining merits, including the deemed dividend question. Case-Laws Income Tax Thu, 06 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211526