https://www.taxtmi.com/caselaws?id=235705 Reopening of a completed assessment is not barred where reassessment is founded on fresh adverse material and reports not examined in the earlier proceeding; mere change of opinion does not arise in that situation. A reassessment is not invalid merely because departmental or technical material was available, provided the assessing officer independently considers the record and applies his own mind rather than acting mechanically on a superior's dictate. However, where adverse material such as vigilance reports, third-party books or seized documents is used against an assessee, it must be disclosed and, where necessary, the affected parties must be confronted and given a fair opportunity of cross-examination. Failure to do so vitiates the assessment for breach of natural justice. en-us Tue, 08 May 2012 00:00:00 +0530 Mon, 11 Aug 2014 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=235705 Reopening of a completed assessment is not barred where reassessment is founded on fresh adverse material and reports not examined in the earlier proceeding; mere change of opinion does not arise in that situation. A reassessment is not invalid merely because departmental or technical material was available, provided the assessing officer independently considers the record and applies his own mind rather than acting mechanically on a superior's dictate. However, where adverse material such as vigilance reports, third-party books or seized documents is used against an assessee, it must be disclosed and, where necessary, the affected parties must be confronted and given a fair opportunity of cross-examination. Failure to do so vitiates the assessment for breach of natural justice. Case-Laws VAT and Sales Tax Tue, 08 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=235705