https://www.taxtmi.com/caselaws?id=434927 Reassessment under section 147 was invalid where the original section 143(3) assessment had already examined the impugned hire charges and the assessee had supplied the relevant details. Reopening on the same record, without fresh or tangible material, amounted to a mere change of opinion and was impermissible in law. An audit objection based only on alleged non-deduction of tax at source did not supply a valid new basis for reopening. The quashing of the reassessment was therefore upheld. en-us Wed, 22 Feb 2023 00:00:00 +0530 Mon, 06 Mar 2023 16:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434927 Reassessment under section 147 was invalid where the original section 143(3) assessment had already examined the impugned hire charges and the assessee had supplied the relevant details. Reopening on the same record, without fresh or tangible material, amounted to a mere change of opinion and was impermissible in law. An audit objection based only on alleged non-deduction of tax at source did not supply a valid new basis for reopening. The quashing of the reassessment was therefore upheld. Case-Laws Income Tax Wed, 22 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434927