https://www.taxtmi.com/caselaws?id=329336 The court held that the re-assessment proceedings initiated by the Assessing Officer (AO) were invalid as they were based on a mere change of opinion without any new material, contravening the requirement of having a "reason to believe" that income had escaped assessment. The court emphasized the necessity of new material for reopening assessments under Sections 147 and 148 of the Income Tax Act. The assessee was found to have fulfilled their duty of disclosing all material facts necessary for assessment, and the AO's attempt to reopen the assessment based on previously available information was deemed impermissible. The court upheld the ITAT's decision, dismissing the Revenue's appeal. en-us Fri, 20 May 2016 00:00:00 +0530 Sat, 13 May 2017 12:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=329336 The court held that the re-assessment proceedings initiated by the Assessing Officer (AO) were invalid as they were based on a mere change of opinion without any new material, contravening the requirement of having a "reason to believe" that income had escaped assessment. The court emphasized the necessity of new material for reopening assessments under Sections 147 and 148 of the Income Tax Act. The assessee was found to have fulfilled their duty of disclosing all material facts necessary for assessment, and the AO's attempt to reopen the assessment based on previously available information was deemed impermissible. The court upheld the ITAT's decision, dismissing the Revenue's appeal. Case-Laws Income Tax Fri, 20 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=329336