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    <title>1996 (5) TMI 3 - Supreme Court</title>
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    <description>SC held that reassessment under s.147(b) was invalid where the Assessing Officer had consciously permitted a change in the assessee&#039;s method of accounting after considering all relevant facts. As there was no subsequent &quot;information&quot; from an external source and the record showed only a mere change of opinion, the statutory precondition for invoking s.147(b) was not satisfied. The principles from earlier precedent on &quot;information&quot; could not justify reopening in such circumstances. The appeals were allowed, the HC judgment was set aside, and the reference was answered in favour of the assessee and against the Revenue.</description>
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    <pubDate>Wed, 01 May 1996 00:00:00 +0530</pubDate>
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      <title>1996 (5) TMI 3 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=5581</link>
      <description>SC held that reassessment under s.147(b) was invalid where the Assessing Officer had consciously permitted a change in the assessee&#039;s method of accounting after considering all relevant facts. As there was no subsequent &quot;information&quot; from an external source and the record showed only a mere change of opinion, the statutory precondition for invoking s.147(b) was not satisfied. The principles from earlier precedent on &quot;information&quot; could not justify reopening in such circumstances. The appeals were allowed, the HC judgment was set aside, and the reference was answered in favour of the assessee and against the Revenue.</description>
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      <pubDate>Wed, 01 May 1996 00:00:00 +0530</pubDate>
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