https://www.taxtmi.com/caselaws?id=395629 Reassessment under section 147 could not be sustained because the reasons to believe were founded on material already on record in the original assessment and no fresh tangible material existed. The alleged non-disclosure of royalty income was factually incorrect, as that income had already been disclosed and offered to tax, while the other reopening grounds had also been examined earlier. On those facts, the Assessing Officer was only seeking to review a completed assessment, and a mere change of opinion could not justify reopening. The reassessment proceedings were therefore invalid and were quashed, with the appeal succeeding and the remaining grounds left undecided. en-us Thu, 28 May 2020 00:00:00 +0530 Sun, 31 May 2020 19:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395629 Reassessment under section 147 could not be sustained because the reasons to believe were founded on material already on record in the original assessment and no fresh tangible material existed. The alleged non-disclosure of royalty income was factually incorrect, as that income had already been disclosed and offered to tax, while the other reopening grounds had also been examined earlier. On those facts, the Assessing Officer was only seeking to review a completed assessment, and a mere change of opinion could not justify reopening. The reassessment proceedings were therefore invalid and were quashed, with the appeal succeeding and the remaining grounds left undecided. Case-Laws Income Tax Thu, 28 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395629