https://www.taxtmi.com/caselaws?id=32173 Bombay HC reiterated that reassessment under Section 147 cannot be based on the same material already examined in the original assessment. Where the Assessing Officer had called for details and considered the relevant items earlier, a later claim that the material was inadvertently not considered does not amount to fresh information. Reopening on that basis would permit the authority to correct its own omission and use reassessment as a review, which the provision does not allow. The notice under Section 148 was therefore invalid, as the proposed reopening was only a change of opinion. en-us Thu, 10 Jul 2008 00:00:00 +0530 Mon, 08 Sep 2025 16:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32173 Bombay HC reiterated that reassessment under Section 147 cannot be based on the same material already examined in the original assessment. Where the Assessing Officer had called for details and considered the relevant items earlier, a later claim that the material was inadvertently not considered does not amount to fresh information. Reopening on that basis would permit the authority to correct its own omission and use reassessment as a review, which the provision does not allow. The notice under Section 148 was therefore invalid, as the proposed reopening was only a change of opinion. Case-Laws Income Tax Thu, 10 Jul 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32173