https://www.taxtmi.com/caselaws?id=440940 Reopening of assessment for failure to deduct TDS was challenged on the ground that the AO had already examined and accepted substantial transport contract expenses during the original assessment; reliance on a subsequent audit objection alone was held to constitute a change of opinion. The legal basis applied is that reassessment cannot be initiated absent new tangible material or a jurisdictional fact, and mere disagreement with an earlier conclusion is impermissible; consequently the reopening under reassessment provisions was invalidated and the decision favoured the taxpayer. en-us Thu, 06 Jul 2023 00:00:00 +0530 Wed, 21 Jan 2026 17:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440940 Reopening of assessment for failure to deduct TDS was challenged on the ground that the AO had already examined and accepted substantial transport contract expenses during the original assessment; reliance on a subsequent audit objection alone was held to constitute a change of opinion. The legal basis applied is that reassessment cannot be initiated absent new tangible material or a jurisdictional fact, and mere disagreement with an earlier conclusion is impermissible; consequently the reopening under reassessment provisions was invalidated and the decision favoured the taxpayer. Case-Laws Income Tax Thu, 06 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440940