https://www.taxtmi.com/caselaws?id=437472 Reassessment based on material already available in the original records, without any new tangible material, was treated as an impermissible change of opinion. The recorded reasons showed that the same factual basis was being re-examined from a different angle, and the objection order also failed to consider an intervening appellate order that had already addressed the disputed issues in the assessee's favour. On that basis, the reopening did not satisfy the statutory threshold for reassessment after the prescribed period, and the notice and rejection order were quashed. en-us Thu, 04 May 2023 00:00:00 +0530 Fri, 23 Jun 2023 17:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437472 Reassessment based on material already available in the original records, without any new tangible material, was treated as an impermissible change of opinion. The recorded reasons showed that the same factual basis was being re-examined from a different angle, and the objection order also failed to consider an intervening appellate order that had already addressed the disputed issues in the assessee's favour. On that basis, the reopening did not satisfy the statutory threshold for reassessment after the prescribed period, and the notice and rejection order were quashed. Case-Laws Income Tax Thu, 04 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437472