https://www.taxtmi.com/caselaws?id=27332 Reassessment under Section 147(b) of the Income-tax Act, 1961 was held invalid where the assessee had disclosed all material facts and the reopening was based solely on an internal audit note. The court treated the attempted reopening as a mere change of opinion, which does not meet the statutory requirement for reassessment. An audit note by itself was not accepted as valid information to justify revisiting an assessment already made on the disclosed record. The reference was answered against the Revenue and in favour of the assessee. en-us Tue, 20 Mar 1984 00:00:00 +0530 Fri, 12 Feb 2010 11:54:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27332 Reassessment under Section 147(b) of the Income-tax Act, 1961 was held invalid where the assessee had disclosed all material facts and the reopening was based solely on an internal audit note. The court treated the attempted reopening as a mere change of opinion, which does not meet the statutory requirement for reassessment. An audit note by itself was not accepted as valid information to justify revisiting an assessment already made on the disclosed record. The reference was answered against the Revenue and in favour of the assessee. Case-Laws Income Tax Tue, 20 Mar 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27332