https://www.taxtmi.com/caselaws?id=418245 Bombay HC held the proposed reopening under s.147 invalid, finding the reasons reflected a mere change of opinion rather than fresh tangible material showing escapement of income. The HC noted the assessment was already considered at s.143(3) scrutiny and s.154 rectification; the approving authority under s.151 should not have sanctioned reopening without proper re-examination. Reassessment within four years requires a live link between reasons and formation of belief; absent fresh material, reopening is prohibited. Decision rendered in favour of the assessee. en-us Thu, 03 Feb 2022 00:00:00 +0530 Sat, 11 Oct 2025 13:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418245 Bombay HC held the proposed reopening under s.147 invalid, finding the reasons reflected a mere change of opinion rather than fresh tangible material showing escapement of income. The HC noted the assessment was already considered at s.143(3) scrutiny and s.154 rectification; the approving authority under s.151 should not have sanctioned reopening without proper re-examination. Reassessment within four years requires a live link between reasons and formation of belief; absent fresh material, reopening is prohibited. Decision rendered in favour of the assessee. Case-Laws Income Tax Thu, 03 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418245