https://www.taxtmi.com/caselaws?id=212882 Reopening of a scrutiny assessment under section 147, where the assessee had disclosed the receipt in the return papers but no specific query had been raised in the original assessment, raised the issue whether the case involved a mere change of opinion or an overlooked point. The Court examined the post-1989 scope of reassessment, the significance of material already on record, and the relevance of the presumption arising from a section 143(3) scrutiny assessment. It concluded that the meaning and application of change of opinion, together with the evidentiary presumption under section 114(e) of the Evidence Act, involved questions of wider importance and referred the matter to a larger Bench. en-us Mon, 23 Apr 2012 00:00:00 +0530 Mon, 09 Jun 2025 12:46:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212882 Reopening of a scrutiny assessment under section 147, where the assessee had disclosed the receipt in the return papers but no specific query had been raised in the original assessment, raised the issue whether the case involved a mere change of opinion or an overlooked point. The Court examined the post-1989 scope of reassessment, the significance of material already on record, and the relevance of the presumption arising from a section 143(3) scrutiny assessment. It concluded that the meaning and application of change of opinion, together with the evidentiary presumption under section 114(e) of the Evidence Act, involved questions of wider importance and referred the matter to a larger Bench. Case-Laws Income Tax Mon, 23 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212882