https://www.taxtmi.com/caselaws?id=285768 Reassessment under sections 147 and 148 could not be sustained where the original scrutiny assessment had already examined mushroom farming income and accepted it as agricultural income on the same material. The Revenue relied on a circular and a different view of "agriculture", but no fresh tangible material had emerged after the section 143(3) assessment. Applying the live-link requirement for reopening, the court treated the notice as founded on a mere change of opinion rather than new information. The section 148 notice and the consequent rejection order were quashed in favour of the assessee. en-us Wed, 11 Apr 2018 00:00:00 +0530 Sat, 25 Jan 2020 08:34:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285768 Reassessment under sections 147 and 148 could not be sustained where the original scrutiny assessment had already examined mushroom farming income and accepted it as agricultural income on the same material. The Revenue relied on a circular and a different view of "agriculture", but no fresh tangible material had emerged after the section 143(3) assessment. Applying the live-link requirement for reopening, the court treated the notice as founded on a mere change of opinion rather than new information. The section 148 notice and the consequent rejection order were quashed in favour of the assessee. Case-Laws Income Tax Wed, 11 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285768