https://www.taxtmi.com/caselaws?id=331385 Reassessment of a completed scrutiny assessment was invalid because the Assessing Officer had already examined foreign commission payments and tax deduction at source during the original section 143(3) proceedings. The recorded reasons for reopening relied only on the same material already on record and disclosed no fresh tangible material after the assessment. On that basis, reopening under sections 147 and 148 amounted to a mere change of opinion, which is impermissible. The notice was therefore quashed and the assessee succeeded. en-us Wed, 10 Aug 2016 00:00:00 +0530 Mon, 22 Aug 2016 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331385 Reassessment of a completed scrutiny assessment was invalid because the Assessing Officer had already examined foreign commission payments and tax deduction at source during the original section 143(3) proceedings. The recorded reasons for reopening relied only on the same material already on record and disclosed no fresh tangible material after the assessment. On that basis, reopening under sections 147 and 148 amounted to a mere change of opinion, which is impermissible. The notice was therefore quashed and the assessee succeeded. Case-Laws Income Tax Wed, 10 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331385