https://www.taxtmi.com/caselaws?id=33584 Reopening completed assessments under sections 147 and 148 requires a genuine basis to believe income has escaped assessment, supported by new tangible material. Where the assessee had already disclosed the relevant agreements and supporting documents, and the Assessing Officer relied on the same material originally examined, a later notice based only on a different inference amounted to a mere change of opinion. On these facts, reassessment could not be sustained because it was a review of an earlier view rather than action founded on fresh information; the section 148 notice was quashed. en-us Mon, 25 May 2009 00:00:00 +0530 Mon, 10 Nov 2025 16:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33584 Reopening completed assessments under sections 147 and 148 requires a genuine basis to believe income has escaped assessment, supported by new tangible material. Where the assessee had already disclosed the relevant agreements and supporting documents, and the Assessing Officer relied on the same material originally examined, a later notice based only on a different inference amounted to a mere change of opinion. On these facts, reassessment could not be sustained because it was a review of an earlier view rather than action founded on fresh information; the section 148 notice was quashed. Case-Laws Income Tax Mon, 25 May 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33584