https://www.taxtmi.com/caselaws?id=432321 Reopening is permissible where the original return was only processed under Section 143(1), because such processing is an intimation and not an assessment, so no prior opinion exists and the doctrine of change of opinion does not apply. In that setting, reasons to believe may be formed from the return and accompanying material without proving fresh tangible material. A prior acceptance of a similar claim in another year did not bar proceedings where the assessee failed to show that the relevant services were identical or supported by underlying contracts or invoices. The reassessment and Section 148A(d) order were therefore left undisturbed. en-us Mon, 22 Aug 2022 00:00:00 +0530 Mon, 02 Jan 2023 14:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432321 Reopening is permissible where the original return was only processed under Section 143(1), because such processing is an intimation and not an assessment, so no prior opinion exists and the doctrine of change of opinion does not apply. In that setting, reasons to believe may be formed from the return and accompanying material without proving fresh tangible material. A prior acceptance of a similar claim in another year did not bar proceedings where the assessee failed to show that the relevant services were identical or supported by underlying contracts or invoices. The reassessment and Section 148A(d) order were therefore left undisturbed. Case-Laws Income Tax Mon, 22 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432321