https://www.taxtmi.com/caselaws?id=414726 Reopening of assessment under section 147 is invalid where the material relied upon for reassessment was already part of the original record and the assessee had not failed to disclose primary facts fully and truly. The actuarial report, including the negative reserve, was furnished during the original proceedings and had already been considered by the Assessing Officer. In the absence of any fresh tangible material, the reassessment was founded only on a different view of the same material, which amounts to a mere change of opinion. The reassessment could not be sustained and the challenge failed. en-us Fri, 22 Oct 2021 00:00:00 +0530 Mon, 10 Oct 2022 11:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414726 Reopening of assessment under section 147 is invalid where the material relied upon for reassessment was already part of the original record and the assessee had not failed to disclose primary facts fully and truly. The actuarial report, including the negative reserve, was furnished during the original proceedings and had already been considered by the Assessing Officer. In the absence of any fresh tangible material, the reassessment was founded only on a different view of the same material, which amounts to a mere change of opinion. The reassessment could not be sustained and the challenge failed. Case-Laws Income Tax Fri, 22 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414726