https://www.taxtmi.com/caselaws?id=432684 Reopening of income-tax assessment was challenged on grounds that the Assessing Officer lacked any new tangible material and merely changed opinion regarding tax treatment of a licence fee capitalized as an intangible asset. The analysis emphasises that entitlement to a specific statutory deduction was not expressly negated in the reasons and that depreciation treatment had effectively been considered and allowed in the original assessment. Because no fresh information or material surfaced between assessment and reopening, the reopening constituted impermissible change of opinion and did not satisfy jurisdictional foundation for reopening; the reopening notice and consequent objection disposal were set aside. en-us Mon, 09 Jan 2023 00:00:00 +0530 Wed, 21 Jan 2026 17:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432684 Reopening of income-tax assessment was challenged on grounds that the Assessing Officer lacked any new tangible material and merely changed opinion regarding tax treatment of a licence fee capitalized as an intangible asset. The analysis emphasises that entitlement to a specific statutory deduction was not expressly negated in the reasons and that depreciation treatment had effectively been considered and allowed in the original assessment. Because no fresh information or material surfaced between assessment and reopening, the reopening constituted impermissible change of opinion and did not satisfy jurisdictional foundation for reopening; the reopening notice and consequent objection disposal were set aside. Case-Laws Income Tax Mon, 09 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432684