https://www.taxtmi.com/caselaws?id=252476 Reassessment under section 147 was held invalid where the original section 143(3) assessment had already examined the deduction claim under section 80IC through specific queries and detailed replies. The Assessing Officer had applied his mind to the same material, and the recorded reopening reasons relied only on the earlier assessment order without any fresh tangible material or live nexus to escaped income. On that basis, reopening amounted to a prohibited change of opinion and an impermissible review of the prior decision. The reassessment notice and consequent order were therefore void, the assessee's appeal was allowed, and the Revenue's appeal was dismissed as infructuous. en-us Fri, 22 Aug 2014 00:00:00 +0530 Mon, 08 Aug 2022 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252476 Reassessment under section 147 was held invalid where the original section 143(3) assessment had already examined the deduction claim under section 80IC through specific queries and detailed replies. The Assessing Officer had applied his mind to the same material, and the recorded reopening reasons relied only on the earlier assessment order without any fresh tangible material or live nexus to escaped income. On that basis, reopening amounted to a prohibited change of opinion and an impermissible review of the prior decision. The reassessment notice and consequent order were therefore void, the assessee's appeal was allowed, and the Revenue's appeal was dismissed as infructuous. Case-Laws Income Tax Fri, 22 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252476