https://www.taxtmi.com/caselaws?id=12568 Reassessment under section 147 cannot be initiated on a mere change of opinion on material already examined in a completed scrutiny assessment. A valid reopening requires a rational basis for "reason to believe" founded on fresh material, external information, or a change in law; the provision does not confer a power of review on the Assessing Officer. An assessment under section 143(3) carries a presumption of application of mind, and the absence of detailed reasons in the assessment order does not, by itself, justify reopening. On these principles, reopening based only on a fresh appraisal of the same facts is impermissible. en-us Fri, 19 Apr 2002 00:00:00 +0530 Tue, 30 Dec 2025 13:01:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12568 Reassessment under section 147 cannot be initiated on a mere change of opinion on material already examined in a completed scrutiny assessment. A valid reopening requires a rational basis for "reason to believe" founded on fresh material, external information, or a change in law; the provision does not confer a power of review on the Assessing Officer. An assessment under section 143(3) carries a presumption of application of mind, and the absence of detailed reasons in the assessment order does not, by itself, justify reopening. On these principles, reopening based only on a fresh appraisal of the same facts is impermissible. Case-Laws Income Tax Fri, 19 Apr 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12568