https://www.taxtmi.com/caselaws?id=216959 Reopening under section 147 after a scrutiny assessment under section 143(3) requires reason to believe that income has escaped assessment, and, where the first proviso applies, failure to fully and truly disclose material facts. The change of opinion bar applies when the Assessing Officer had already formed a view on the material and later seeks a different view on the same material. Lack of discussion in the assessment order does not by itself show no opinion, because regularity of official acts may be presumed under section 114(e) of the Evidence Act. On full disclosure and no tangible new material, reopening would amount to an impermissible review; section 263 is the proper remedy for an erroneous assessment. en-us Fri, 21 Sep 2012 00:00:00 +0530 Wed, 13 Aug 2025 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216959 Reopening under section 147 after a scrutiny assessment under section 143(3) requires reason to believe that income has escaped assessment, and, where the first proviso applies, failure to fully and truly disclose material facts. The change of opinion bar applies when the Assessing Officer had already formed a view on the material and later seeks a different view on the same material. Lack of discussion in the assessment order does not by itself show no opinion, because regularity of official acts may be presumed under section 114(e) of the Evidence Act. On full disclosure and no tangible new material, reopening would amount to an impermissible review; section 263 is the proper remedy for an erroneous assessment. Case-Laws Income Tax Fri, 21 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216959