https://www.taxtmi.com/caselaws?id=2063 Where all relevant material was disclosed in the original Section 143(3) assessment, reassessment could not be reopened merely because the Assessing Officer later took a different view of the same facts. The High Court held that once the material was before the Assessing Officer and had been examined, the absence of an express finding on every aspect in the assessment order did not imply non-disclosure. Reopening on the same record would amount only to a change of opinion, which is impermissible. The challenge to reopening therefore failed. en-us Tue, 22 May 2007 00:00:00 +0530 Mon, 15 Sep 2025 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=2063 Where all relevant material was disclosed in the original Section 143(3) assessment, reassessment could not be reopened merely because the Assessing Officer later took a different view of the same facts. The High Court held that once the material was before the Assessing Officer and had been examined, the absence of an express finding on every aspect in the assessment order did not imply non-disclosure. Reopening on the same record would amount only to a change of opinion, which is impermissible. The challenge to reopening therefore failed. Case-Laws Income Tax Tue, 22 May 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=2063