https://www.taxtmi.com/caselaws?id=252074 Reopening of completed assessments under section 147 requires fresh tangible material forming an objective reason to believe that income has escaped assessment; a mere change of opinion on material already on record is insufficient. As the reassessment reasons rested on the same balance-sheet material that had already been considered in the original section 143(3) assessments, no external or new material supported jurisdiction under section 148. The reassessment notices were therefore invalid, the reassessment orders were unsustainable, and the assessee succeeded on the reopening challenge. en-us Fri, 05 Sep 2014 00:00:00 +0530 Mon, 22 Feb 2016 12:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252074 Reopening of completed assessments under section 147 requires fresh tangible material forming an objective reason to believe that income has escaped assessment; a mere change of opinion on material already on record is insufficient. As the reassessment reasons rested on the same balance-sheet material that had already been considered in the original section 143(3) assessments, no external or new material supported jurisdiction under section 148. The reassessment notices were therefore invalid, the reassessment orders were unsustainable, and the assessee succeeded on the reopening challenge. Case-Laws Income Tax Fri, 05 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252074