https://www.taxtmi.com/caselaws?id=446661 HC held that reassessment under s.147 was invalid because the material relied on in the second round was identical to that examined in the original assessment; allegations regarding the accommodation entry and its source were the same, amounting to a mere change of opinion. The AO had raised and considered the query in the first assessment, and absent fresh material not available earlier, reopening was impermissible. The court concluded the reassessment proceedings were invalid and decided in favour of the assessee. en-us Tue, 07 Nov 2023 00:00:00 +0530 Sat, 20 Sep 2025 11:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446661 HC held that reassessment under s.147 was invalid because the material relied on in the second round was identical to that examined in the original assessment; allegations regarding the accommodation entry and its source were the same, amounting to a mere change of opinion. The AO had raised and considered the query in the first assessment, and absent fresh material not available earlier, reopening was impermissible. The court concluded the reassessment proceedings were invalid and decided in favour of the assessee. Case-Laws Income Tax Tue, 07 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446661