https://www.taxtmi.com/caselaws?id=293140 Reassessment under sections 147 and 148 cannot rest on the same material already examined in a scrutiny assessment under section 143(3) where the Assessing Officer had issued detailed queries, considered the assessee's replies, and accepted the return. In that situation, reopening requires fresh tangible material giving a prima facie reason to believe that income has escaped assessment; otherwise it becomes a review under the guise of reassessment and is hit by the change of opinion principle. The proviso to section 147 also limits reopening beyond four years unless there was failure to disclose fully and truly all material facts. On the stated facts, the reopening was invalid. en-us Mon, 13 Aug 2018 00:00:00 +0530 Wed, 13 Nov 2024 11:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293140 Reassessment under sections 147 and 148 cannot rest on the same material already examined in a scrutiny assessment under section 143(3) where the Assessing Officer had issued detailed queries, considered the assessee's replies, and accepted the return. In that situation, reopening requires fresh tangible material giving a prima facie reason to believe that income has escaped assessment; otherwise it becomes a review under the guise of reassessment and is hit by the change of opinion principle. The proviso to section 147 also limits reopening beyond four years unless there was failure to disclose fully and truly all material facts. On the stated facts, the reopening was invalid. Case-Laws Income Tax Mon, 13 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293140