https://www.taxtmi.com/caselaws?id=409291 Reassessment under sections 147 and 148 could not be sustained where a scrutiny assessment under section 143(3) had already examined the return, accounts, audit report and notes, and the reopening relied on no fresh tangible material. The reassessment reasons merely re-examined the same material previously considered, so the statutory "reason to believe" requirement was not met and the action amounted to an impermissible change of opinion. The reassessment notice and order were therefore quashed, while the merits of the additions were left undecided. en-us Thu, 17 Jun 2021 00:00:00 +0530 Mon, 05 Jul 2021 08:25:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409291 Reassessment under sections 147 and 148 could not be sustained where a scrutiny assessment under section 143(3) had already examined the return, accounts, audit report and notes, and the reopening relied on no fresh tangible material. The reassessment reasons merely re-examined the same material previously considered, so the statutory "reason to believe" requirement was not met and the action amounted to an impermissible change of opinion. The reassessment notice and order were therefore quashed, while the merits of the additions were left undecided. Case-Laws Income Tax Thu, 17 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409291