https://www.taxtmi.com/article/detailed?id=7984 Reassessment cannot be sustained merely because the assessing officer has formed a different opinion where all relevant facts and enquiries were considered in the original assessment; the Supreme Court affirmed that notices issued and reassessments initiated on the same record, absent new tangible material, are void. The reported decision involved allowance of deductions in the original assessment, subsequent challenge based only on re-allocation of expenses from the same record, and rejection of reassessment as founded on change of opinion. The author recommends procedural reforms including a monetary threshold, recorded reasons with notice, and an opportunity to present objections before proceeding. en-us Tue, 01 May 2018 15:58:39 +0530 Tue, 01 May 2018 15:58:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=7984 Reassessment cannot be sustained merely because the assessing officer has formed a different opinion where all relevant facts and enquiries were considered in the original assessment; the Supreme Court affirmed that notices issued and reassessments initiated on the same record, absent new tangible material, are void. The reported decision involved allowance of deductions in the original assessment, subsequent challenge based only on re-allocation of expenses from the same record, and rejection of reassessment as founded on change of opinion. The author recommends procedural reforms including a monetary threshold, recorded reasons with notice, and an opportunity to present objections before proceeding. Articles Income Tax Tue, 01 May 2018 15:58:39 +0530 https://www.taxtmi.com/article/detailed?id=7984