https://www.taxtmi.com/caselaws?id=267372 Reassessment is invalid where the Assessing Officer relies only on a re-examination of the original assessment record and not on fresh tangible material that came to light after completion of the assessment. The statutory trigger for reopening is objective new material giving rise to a rational belief that income has escaped assessment; without it, the assumption of jurisdiction fails. In such circumstances, reopening amounts to an impermissible review and the question of mere change of opinion does not arise. The reassessment was therefore quashed as bad in law for want of fresh tangible material. en-us Tue, 22 Sep 2015 00:00:00 +0530 Sat, 30 Apr 2016 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=267372 Reassessment is invalid where the Assessing Officer relies only on a re-examination of the original assessment record and not on fresh tangible material that came to light after completion of the assessment. The statutory trigger for reopening is objective new material giving rise to a rational belief that income has escaped assessment; without it, the assumption of jurisdiction fails. In such circumstances, reopening amounts to an impermissible review and the question of mere change of opinion does not arise. The reassessment was therefore quashed as bad in law for want of fresh tangible material. Case-Laws Income Tax Tue, 22 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=267372