https://www.taxtmi.com/caselaws?id=29000 The case involved a challenge to the reopening of an assessment by the Income-tax Officer under sections 148 and 147(b) of the Income-tax Act, 1961. The Appellate Tribunal held that the reassessment was a mere change of opinion and not based on new information, dismissing the Revenue's appeal. The Court clarified that the opinion of an internal audit party does not constitute 'information' for reopening assessments, emphasizing the need for independent determination by the ITO. Ultimately, the decision favored the assessee, ruling that the reassessment lacked fresh information required by section 147(b). en-us Mon, 17 Aug 1981 00:00:00 +0530 Wed, 10 Mar 2010 11:22:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29000 The case involved a challenge to the reopening of an assessment by the Income-tax Officer under sections 148 and 147(b) of the Income-tax Act, 1961. The Appellate Tribunal held that the reassessment was a mere change of opinion and not based on new information, dismissing the Revenue's appeal. The Court clarified that the opinion of an internal audit party does not constitute 'information' for reopening assessments, emphasizing the need for independent determination by the ITO. Ultimately, the decision favored the assessee, ruling that the reassessment lacked fresh information required by section 147(b). Case-Laws Income Tax Mon, 17 Aug 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29000