https://www.taxtmi.com/caselaws?id=218295 Reopening of assessment under sections 147 and 148 on the basis of the same material already examined in the original section 143(3) assessment was invalid. The Assessing Officer had considered the relevant details relating to section 80HHC deduction earlier, and the reassessment sought only to reappraise the same receipts and expenses. That amounted to a mere change of opinion, not fresh tangible material. An audit objection on a question of law could not, by itself, constitute valid information for reopening. The reassessment was therefore held to be null and void, and the revenue's challenge failed. en-us Fri, 08 Jun 2012 00:00:00 +0530 Tue, 28 May 2013 10:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218295 Reopening of assessment under sections 147 and 148 on the basis of the same material already examined in the original section 143(3) assessment was invalid. The Assessing Officer had considered the relevant details relating to section 80HHC deduction earlier, and the reassessment sought only to reappraise the same receipts and expenses. That amounted to a mere change of opinion, not fresh tangible material. An audit objection on a question of law could not, by itself, constitute valid information for reopening. The reassessment was therefore held to be null and void, and the revenue's challenge failed. Case-Laws Income Tax Fri, 08 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218295