https://www.taxtmi.com/caselaws?id=371857 Reassessment under section 147 was held invalid where the original scrutiny assessment had already examined the non-charging of interest on a loan to a sister concern, and the assessee's explanation had been accepted. Because no fresh tangible material emerged after completion of the original assessment, reopening on the same material amounted to a mere change of opinion, which is impermissible. The Tribunal also accepted that the interest was not actually realised and that the commercial reality of the transaction supported the assessee's treatment on the basis of real income. The notional interest addition therefore did not survive. en-us Fri, 07 Sep 2018 00:00:00 +0530 Thu, 13 Dec 2018 14:04:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=371857 Reassessment under section 147 was held invalid where the original scrutiny assessment had already examined the non-charging of interest on a loan to a sister concern, and the assessee's explanation had been accepted. Because no fresh tangible material emerged after completion of the original assessment, reopening on the same material amounted to a mere change of opinion, which is impermissible. The Tribunal also accepted that the interest was not actually realised and that the commercial reality of the transaction supported the assessee's treatment on the basis of real income. The notional interest addition therefore did not survive. Case-Laws Income Tax Fri, 07 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=371857