https://www.taxtmi.com/caselaws?id=252325 Reassessment under section 147 was invalid where it rested on the same seized material and facts already examined in the original assessment. The original assessment had considered the property investment evidence and the assessee's explanation, and no fresh tangible material or new information emerged later. On those facts, reopening on a different view of the same record amounted to a mere change of opinion, which cannot justify reassessment. If the earlier assessment was considered erroneous and prejudicial to revenue, the appropriate remedy would have been proceedings under section 263 rather than reopening under section 147. en-us Fri, 28 Feb 2014 00:00:00 +0530 Mon, 06 Oct 2014 10:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252325 Reassessment under section 147 was invalid where it rested on the same seized material and facts already examined in the original assessment. The original assessment had considered the property investment evidence and the assessee's explanation, and no fresh tangible material or new information emerged later. On those facts, reopening on a different view of the same record amounted to a mere change of opinion, which cannot justify reassessment. If the earlier assessment was considered erroneous and prejudicial to revenue, the appropriate remedy would have been proceedings under section 263 rather than reopening under section 147. Case-Laws Income Tax Fri, 28 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252325