https://www.taxtmi.com/caselaws?id=358465 Where an Assessing Officer has already examined a deduction claim in a section 143(3) assessment after specific queries and replies, reassessment under sections 147 and 148 cannot be used to revisit the same material merely to take a different view or correct an earlier omission. The recorded reasons must disclose a valid basis for reopening, and the power cannot operate as a review of a conscious earlier decision. Because the deduction issue had been enquired into in the original assessment, the later notice was treated as a change of opinion and the reopening was invalid; the assessee succeeded. en-us Tue, 03 Apr 2018 00:00:00 +0530 Thu, 04 Apr 2019 18:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358465 Where an Assessing Officer has already examined a deduction claim in a section 143(3) assessment after specific queries and replies, reassessment under sections 147 and 148 cannot be used to revisit the same material merely to take a different view or correct an earlier omission. The recorded reasons must disclose a valid basis for reopening, and the power cannot operate as a review of a conscious earlier decision. Because the deduction issue had been enquired into in the original assessment, the later notice was treated as a change of opinion and the reopening was invalid; the assessee succeeded. Case-Laws Income Tax Tue, 03 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358465