https://www.taxtmi.com/caselaws?id=366689 Reassessment under Section 147 requires the Assessing Officer to have independent reason to believe, supported by tangible material, that income has escaped assessment. Where a scrutiny assessment under Section 143(3) had already examined the same expenditure claim, reopening cannot rest on a mere change of opinion, even if the earlier order did not discuss the issue in detail. If the recorded reasons substantially reproduce an audit objection and the officer had earlier disagreed with that view, there is no live link between the material and the belief of escapement. The reopening was therefore invalid. en-us Fri, 10 Aug 2018 00:00:00 +0530 Sat, 08 Sep 2018 08:09:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=366689 Reassessment under Section 147 requires the Assessing Officer to have independent reason to believe, supported by tangible material, that income has escaped assessment. Where a scrutiny assessment under Section 143(3) had already examined the same expenditure claim, reopening cannot rest on a mere change of opinion, even if the earlier order did not discuss the issue in detail. If the recorded reasons substantially reproduce an audit objection and the officer had earlier disagreed with that view, there is no live link between the material and the belief of escapement. The reopening was therefore invalid. Case-Laws Income Tax Fri, 10 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=366689