https://www.taxtmi.com/caselaws?id=351981 Reassessment under Section 147 was upheld because the Assessing Officer had tangible material to believe income had escaped assessment, and the bar on change of opinion did not apply where the original assessment had not consciously examined the assessee's associate-enterprise transactions or the need to refer Form 3CEB to the transfer pricing officer. The court noted that the reopening was based on omissions in the original assessment, not a mere review of an earlier considered view, and the objections were disposed of by a reasoned order. The challenge to the notice and the objection order therefore failed. en-us Fri, 03 Nov 2017 00:00:00 +0530 Sat, 24 Feb 2018 14:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=351981 Reassessment under Section 147 was upheld because the Assessing Officer had tangible material to believe income had escaped assessment, and the bar on change of opinion did not apply where the original assessment had not consciously examined the assessee's associate-enterprise transactions or the need to refer Form 3CEB to the transfer pricing officer. The court noted that the reopening was based on omissions in the original assessment, not a mere review of an earlier considered view, and the objections were disposed of by a reasoned order. The challenge to the notice and the objection order therefore failed. Case-Laws Income Tax Fri, 03 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=351981