https://www.taxtmi.com/caselaws?id=253364 The Tribunal dismissed the revenue's appeal, upholding the CIT(A)'s decision that the reopening of the assessment under Section 147 was invalid as it was based on a mere change of opinion. The original assessment had already examined and considered the prior period and exceptional items, and there was no new tangible material to justify the reopening. The Tribunal's decision reinforced the principle that an assessment cannot be reopened merely for a reappraisal of the same materials considered during the original assessment. en-us Wed, 19 Nov 2014 00:00:00 +0530 Sat, 22 Nov 2014 08:27:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253364 The Tribunal dismissed the revenue's appeal, upholding the CIT(A)'s decision that the reopening of the assessment under Section 147 was invalid as it was based on a mere change of opinion. The original assessment had already examined and considered the prior period and exceptional items, and there was no new tangible material to justify the reopening. The Tribunal's decision reinforced the principle that an assessment cannot be reopened merely for a reappraisal of the same materials considered during the original assessment. Case-Laws Income Tax Wed, 19 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253364