https://www.taxtmi.com/caselaws?id=414159 Reassessment was held unsustainable where the original scrutiny assessment had already considered the actuarial report and related material, including the negative reserve. Reopening on the same material amounted to a mere change of opinion, not discovery of new facts. The record also showed no tangible material indicating that the assessee failed to fully and truly disclose material facts necessary for assessment. In the absence of such material, the statutory conditions for reopening were not met, and the addition based on the negative reserve did not survive once the reassessment was invalidated. en-us Sat, 23 Oct 2021 00:00:00 +0530 Fri, 29 Oct 2021 08:40:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414159 Reassessment was held unsustainable where the original scrutiny assessment had already considered the actuarial report and related material, including the negative reserve. Reopening on the same material amounted to a mere change of opinion, not discovery of new facts. The record also showed no tangible material indicating that the assessee failed to fully and truly disclose material facts necessary for assessment. In the absence of such material, the statutory conditions for reopening were not met, and the addition based on the negative reserve did not survive once the reassessment was invalidated. Case-Laws Income Tax Sat, 23 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414159