https://www.taxtmi.com/caselaws?id=26926 Reassessment cannot be founded on a mere change of opinion where the assessee fully disclosed the primary facts and the exchange-loss claim was already examined in the original assessments; reopening on that ground was therefore without jurisdiction. A separate enquiry into head office expenses and service charges was permissible because that ceiling issue had not been examined earlier, so the notice could stand only to that limited extent. A later writ challenge to the 1970-71 reassessment, including gratuity disallowance, was declined because of delay and the availability of statutory appellate remedies, leaving those matters to the tax authorities. en-us Tue, 18 Dec 1984 00:00:00 +0530 Tue, 09 Feb 2010 14:55:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26926 Reassessment cannot be founded on a mere change of opinion where the assessee fully disclosed the primary facts and the exchange-loss claim was already examined in the original assessments; reopening on that ground was therefore without jurisdiction. A separate enquiry into head office expenses and service charges was permissible because that ceiling issue had not been examined earlier, so the notice could stand only to that limited extent. A later writ challenge to the 1970-71 reassessment, including gratuity disallowance, was declined because of delay and the availability of statutory appellate remedies, leaving those matters to the tax authorities. Case-Laws Income Tax Tue, 18 Dec 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26926