https://www.taxtmi.com/caselaws?id=19051 Reopening of assessment under section 147(b) was valid because the Assessing Officer independently applied his mind to the material and formed his own belief that the earlier set-off of business loss was not proper. The court distinguished cases where reassessment rests merely on an audit party's opinion, and accepted the finding that the officer did not act mechanically on the audit note. The businesses had been closed long before the relevant assessment year, and that factual position supported the conclusion that reassessment was permissible. en-us Thu, 09 Mar 1995 00:00:00 +0530 Tue, 03 Nov 2009 16:34:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19051 Reopening of assessment under section 147(b) was valid because the Assessing Officer independently applied his mind to the material and formed his own belief that the earlier set-off of business loss was not proper. The court distinguished cases where reassessment rests merely on an audit party's opinion, and accepted the finding that the officer did not act mechanically on the audit note. The businesses had been closed long before the relevant assessment year, and that factual position supported the conclusion that reassessment was permissible. Case-Laws Income Tax Thu, 09 Mar 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19051