https://www.taxtmi.com/caselaws?id=215994 Reassessment under section 147 was held unsustainable where the original scrutiny assessment had already considered the deduction claim, the claim was reflected in the return and computation, and no fresh tangible material emerged; reopening on the same material was treated as a mere change of opinion. On the deduction issue, embroidery on cloth was treated as manufacturing because the process produced commercially distinct end products with a different character and identity from the input material. The assessee therefore succeeded on both issues, with the Revenue's appeal rejected and the cross-objection not surviving. en-us Fri, 15 Jun 2012 00:00:00 +0530 Fri, 24 Aug 2012 12:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215994 Reassessment under section 147 was held unsustainable where the original scrutiny assessment had already considered the deduction claim, the claim was reflected in the return and computation, and no fresh tangible material emerged; reopening on the same material was treated as a mere change of opinion. On the deduction issue, embroidery on cloth was treated as manufacturing because the process produced commercially distinct end products with a different character and identity from the input material. The assessee therefore succeeded on both issues, with the Revenue's appeal rejected and the cross-objection not surviving. Case-Laws Income Tax Fri, 15 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215994