https://www.taxtmi.com/caselaws?id=250057 A completed scrutiny assessment under section 143(3) cannot be reopened under sections 147 and 148 where the assessee had made full disclosure, the Assessing Officer had already examined the issue in detail, and no fresh tangible material emerged. Reopening based only on an internal audit objection and the same material amounts to a mere change of opinion, which is impermissible. As the recorded reasons did not allege any failure to disclose fully and truly all material facts, the notice issued under section 148 was without jurisdiction and was quashed. en-us Wed, 30 Jul 2014 00:00:00 +0530 Fri, 10 Oct 2014 13:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=250057 A completed scrutiny assessment under section 143(3) cannot be reopened under sections 147 and 148 where the assessee had made full disclosure, the Assessing Officer had already examined the issue in detail, and no fresh tangible material emerged. Reopening based only on an internal audit objection and the same material amounts to a mere change of opinion, which is impermissible. As the recorded reasons did not allege any failure to disclose fully and truly all material facts, the notice issued under section 148 was without jurisdiction and was quashed. Case-Laws Income Tax Wed, 30 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=250057