https://www.taxtmi.com/caselaws?id=343255 Reassessment under Sections 147 and 148 of the Income-tax Act was held impermissible where the original scrutiny assessments under Section 143(3) had already examined the transactions through detailed questionnaires and no fresh tangible material emerged. The court noted that the successor Assessing Officer merely revisited the same facts and adopted a different view on the taxability of receipts as fees for technical services. Where the assessee had disclosed all material facts fully and truly and the original assessment showed application of mind, reopening on a mere change of opinion fails the statutory pre-condition for jurisdiction. Reopening was therefore invalid. en-us Thu, 18 May 2017 00:00:00 +0530 Tue, 01 Aug 2017 10:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343255 Reassessment under Sections 147 and 148 of the Income-tax Act was held impermissible where the original scrutiny assessments under Section 143(3) had already examined the transactions through detailed questionnaires and no fresh tangible material emerged. The court noted that the successor Assessing Officer merely revisited the same facts and adopted a different view on the taxability of receipts as fees for technical services. Where the assessee had disclosed all material facts fully and truly and the original assessment showed application of mind, reopening on a mere change of opinion fails the statutory pre-condition for jurisdiction. Reopening was therefore invalid. Case-Laws Income Tax Thu, 18 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343255