https://www.taxtmi.com/caselaws?id=30771 A reassessment notice under section 148 was invalid where the original section 143(3) assessment had allowed deduction under section 80HHC and the Revenue sought to reopen on the same material. A regular assessment carries a presumption that the Assessing Officer applied his mind, and a successor officer cannot reopen merely because a different view is later taken on identical facts. Reopening after four years was also barred because there was no indication that the assessee failed to disclose fully and truly all material facts necessary for assessment. The reassessment proceedings were held unjustified. en-us Mon, 30 Jul 2007 00:00:00 +0530 Tue, 23 Sep 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=30771 A reassessment notice under section 148 was invalid where the original section 143(3) assessment had allowed deduction under section 80HHC and the Revenue sought to reopen on the same material. A regular assessment carries a presumption that the Assessing Officer applied his mind, and a successor officer cannot reopen merely because a different view is later taken on identical facts. Reopening after four years was also barred because there was no indication that the assessee failed to disclose fully and truly all material facts necessary for assessment. The reassessment proceedings were held unjustified. Case-Laws Income Tax Mon, 30 Jul 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=30771