https://www.taxtmi.com/caselaws?id=413466 Reopening of assessment under Section 147 was held invalid where the Assessing Officer relied on the same materials available at the original assessment, constituting a change of opinion; consequence: reassessment overturned. The absence of any new facts coming to the AOs knowledge post-assessment was decisive, and all grounds were traced to the return and annexures. Further, the AO delayed furnishing reasons for reopening despite requests, contrary to the requirement to provide reasons within a reasonable time as reflected in GKN Driveshafts, which contributed to invalidating the reassessment in favour of the assessee. en-us Tue, 05 Oct 2021 00:00:00 +0530 Wed, 21 Jan 2026 17:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413466 Reopening of assessment under Section 147 was held invalid where the Assessing Officer relied on the same materials available at the original assessment, constituting a change of opinion; consequence: reassessment overturned. The absence of any new facts coming to the AOs knowledge post-assessment was decisive, and all grounds were traced to the return and annexures. Further, the AO delayed furnishing reasons for reopening despite requests, contrary to the requirement to provide reasons within a reasonable time as reflected in GKN Driveshafts, which contributed to invalidating the reassessment in favour of the assessee. Case-Laws Income Tax Tue, 05 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413466