https://www.taxtmi.com/caselaws?id=35330 HC held that reassessment proceedings initiated u/s 147/148 were without jurisdiction as they were based solely on a change of opinion. In the original scrutiny, the Assessing Officer had specifically examined the assessee's treatment of Rs. 5 per bottle credited to the Transport Infrastructure Utilization Fund (TIUF), including detailed queries and replies. There was no allegation of failure to make full and true disclosure of material facts. Since the issue had already been considered and accepted in the original assessments for AYs 1997-98 and 1998-99, reopening was impermissible. Accordingly, the notices and consequential proceedings were quashed, without adjudicating the merits of taxability of TIUF. en-us Mon, 25 Jan 2010 00:00:00 +0530 Mon, 01 Dec 2025 15:37:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35330 HC held that reassessment proceedings initiated u/s 147/148 were without jurisdiction as they were based solely on a change of opinion. In the original scrutiny, the Assessing Officer had specifically examined the assessee's treatment of Rs. 5 per bottle credited to the Transport Infrastructure Utilization Fund (TIUF), including detailed queries and replies. There was no allegation of failure to make full and true disclosure of material facts. Since the issue had already been considered and accepted in the original assessments for AYs 1997-98 and 1998-99, reopening was impermissible. Accordingly, the notices and consequential proceedings were quashed, without adjudicating the merits of taxability of TIUF. Case-Laws Income Tax Mon, 25 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35330