https://www.taxtmi.com/caselaws?id=265549 Reassessment notices under sections 147/148 were quashed because the original assessments under section 143(3) had already examined the same advertising and distribution revenue material after a detailed questionnaire and supporting replies. The recorded reasons showed no fresh tangible material or later-discovered information; they merely sought to reappreciate the existing record and adopt a different view. That amounted to a change of opinion, so the statutory requirement of a valid reason to believe was not met. The orders disposing of objections were also set aside, and the writ petitions were allowed. en-us Thu, 08 Oct 2015 00:00:00 +0530 Tue, 03 May 2016 11:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=265549 Reassessment notices under sections 147/148 were quashed because the original assessments under section 143(3) had already examined the same advertising and distribution revenue material after a detailed questionnaire and supporting replies. The recorded reasons showed no fresh tangible material or later-discovered information; they merely sought to reappreciate the existing record and adopt a different view. That amounted to a change of opinion, so the statutory requirement of a valid reason to believe was not met. The orders disposing of objections were also set aside, and the writ petitions were allowed. Case-Laws Income Tax Thu, 08 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=265549