https://www.taxtmi.com/caselaws?id=258420 Reassessment cannot be sustained where the material relied on for reopening was already fully disclosed, specifically called for, and examined in the original assessment. The return, financial statements, tax audit report, transfer pricing documents, and replies to the Assessing Officer's questionnaire had disclosed the royalty and technical fee transactions, which were also considered by the Transfer Pricing Officer. In the absence of any new tangible material, reopening on the same facts amounted only to a change of opinion, and the power to reassess could not be used as a power to review. The notice and the order rejecting objections were therefore invalid and quashed. en-us Tue, 10 Mar 2015 00:00:00 +0530 Sat, 07 Nov 2015 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258420 Reassessment cannot be sustained where the material relied on for reopening was already fully disclosed, specifically called for, and examined in the original assessment. The return, financial statements, tax audit report, transfer pricing documents, and replies to the Assessing Officer's questionnaire had disclosed the royalty and technical fee transactions, which were also considered by the Transfer Pricing Officer. In the absence of any new tangible material, reopening on the same facts amounted only to a change of opinion, and the power to reassess could not be used as a power to review. The notice and the order rejecting objections were therefore invalid and quashed. Case-Laws Income Tax Tue, 10 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258420