https://www.taxtmi.com/caselaws?id=179272 Reassessment under section 147 issued beyond four years after a completed section 143(3) assessment was impermissible where the Assessing Officer had no fresh information or tangible material after the original proceedings. The proposed disallowance under section 40A(3) had already been considered, so reopening on the same material amounted to a mere change of opinion, which cannot support reassessment jurisdiction. On these facts, the reassessment notice was invalid and the reopening was quashed in favour of the assessee. en-us Wed, 08 Jan 2014 00:00:00 +0530 Thu, 25 Feb 2016 10:03:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179272 Reassessment under section 147 issued beyond four years after a completed section 143(3) assessment was impermissible where the Assessing Officer had no fresh information or tangible material after the original proceedings. The proposed disallowance under section 40A(3) had already been considered, so reopening on the same material amounted to a mere change of opinion, which cannot support reassessment jurisdiction. On these facts, the reassessment notice was invalid and the reopening was quashed in favour of the assessee. Case-Laws Income Tax Wed, 08 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179272