https://www.taxtmi.com/caselaws?id=211630 Reassessment under Sections 147 and 148 may be initiated within four years on the basis of a judicial decision, including where exemption under Section 10(29) is questioned for receipts allegedly unrelated to warehousing. The decisive issue is whether the Assessing Officer's stated basis-multiple distinguishable businesses and ineligible receipts-had already been examined during the original scrutiny assessment under Section 143(3). If it had, reopening would amount to a prohibited change of opinion; if not, it may rest on fresh material. The Tribunal was required to reconsider this limited issue. en-us Fri, 14 Jan 2011 00:00:00 +0530 Wed, 28 Mar 2012 08:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211630 Reassessment under Sections 147 and 148 may be initiated within four years on the basis of a judicial decision, including where exemption under Section 10(29) is questioned for receipts allegedly unrelated to warehousing. The decisive issue is whether the Assessing Officer's stated basis-multiple distinguishable businesses and ineligible receipts-had already been examined during the original scrutiny assessment under Section 143(3). If it had, reopening would amount to a prohibited change of opinion; if not, it may rest on fresh material. The Tribunal was required to reconsider this limited issue. Case-Laws Income Tax Fri, 14 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211630