https://www.taxtmi.com/caselaws?id=267106 Reassessment after a completed scrutiny assessment under section 143(3) cannot be sustained on the same material where the recorded reasons merely re-examine issues already considered, as that is a change of opinion and is impermissible. Where the first proviso to section 147 applies, the reasons for reopening must specifically identify which primary material facts were not fully and truly disclosed by the assessee; a general allegation of non-disclosure is insufficient. On the stated facts, the original assessment had already considered royalty receipts, permanent establishment, and treaty attribution, so the reopening was invalid and the reassessment proceedings were quashed. en-us Thu, 08 Oct 2015 00:00:00 +0530 Tue, 03 May 2016 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=267106 Reassessment after a completed scrutiny assessment under section 143(3) cannot be sustained on the same material where the recorded reasons merely re-examine issues already considered, as that is a change of opinion and is impermissible. Where the first proviso to section 147 applies, the reasons for reopening must specifically identify which primary material facts were not fully and truly disclosed by the assessee; a general allegation of non-disclosure is insufficient. On the stated facts, the original assessment had already considered royalty receipts, permanent establishment, and treaty attribution, so the reopening was invalid and the reassessment proceedings were quashed. Case-Laws Income Tax Thu, 08 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=267106