https://www.taxtmi.com/caselaws?id=219483 Reassessment under section 147 requires recorded reasons supported by tangible material indicating escapement of income; reopening cannot rest only on material already disclosed in the original return. The assessee had already disclosed the interest income and treaty exemption claim, and the reasons for reopening referred only to that same material without any fresh information coming to the Assessing Officer's notice. Because the original return had been processed under section 143(1) did not by itself justify reassessment, the reopening was held invalid and the proceedings under section 147 were quashed in favour of the assessee. en-us Fri, 30 Nov 2012 00:00:00 +0530 Fri, 14 Dec 2012 11:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219483 Reassessment under section 147 requires recorded reasons supported by tangible material indicating escapement of income; reopening cannot rest only on material already disclosed in the original return. The assessee had already disclosed the interest income and treaty exemption claim, and the reasons for reopening referred only to that same material without any fresh information coming to the Assessing Officer's notice. Because the original return had been processed under section 143(1) did not by itself justify reassessment, the reopening was held invalid and the proceedings under section 147 were quashed in favour of the assessee. Case-Laws Income Tax Fri, 30 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219483