https://www.taxtmi.com/caselaws?id=437151 HC held reassessment under s.147 invalid where AO relied on information already on record after framing an s.143(3) scrutiny assessment. The court found no new material or audit objection triggering reopening; the alleged error arose from AO's misappreciation of disclosed primary facts (loss on sale of fixed assets). Reassessment powers do not permit correction of such appreciation errors, and prior concessions by revenue could not cure the jurisdictional defect. Decision in favour of the assessee. en-us Thu, 23 Mar 2023 00:00:00 +0530 Sat, 20 Sep 2025 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437151 HC held reassessment under s.147 invalid where AO relied on information already on record after framing an s.143(3) scrutiny assessment. The court found no new material or audit objection triggering reopening; the alleged error arose from AO's misappreciation of disclosed primary facts (loss on sale of fixed assets). Reassessment powers do not permit correction of such appreciation errors, and prior concessions by revenue could not cure the jurisdictional defect. Decision in favour of the assessee. Case-Laws Income Tax Thu, 23 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437151