https://www.taxtmi.com/caselaws?id=178824 Reassessment under sections 147 and 148 was treated as impermissible where the original assessment under section 143(3) had been completed on the basis of full disclosure of primary facts and no new tangible material had emerged. The reopening relied only on material already available to the Assessing Officer, so it amounted to a mere change of opinion rather than a valid jurisdictional basis for reassessment. The presumption under section 114(e) of the Indian Evidence Act supported the view that the original assessment had been made after due consideration of the disclosed facts. The notice under section 148 was therefore quashed. en-us Fri, 13 Dec 2013 00:00:00 +0530 Mon, 26 Sep 2016 14:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178824 Reassessment under sections 147 and 148 was treated as impermissible where the original assessment under section 143(3) had been completed on the basis of full disclosure of primary facts and no new tangible material had emerged. The reopening relied only on material already available to the Assessing Officer, so it amounted to a mere change of opinion rather than a valid jurisdictional basis for reassessment. The presumption under section 114(e) of the Indian Evidence Act supported the view that the original assessment had been made after due consideration of the disclosed facts. The notice under section 148 was therefore quashed. Case-Laws Income Tax Fri, 13 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178824