https://www.taxtmi.com/caselaws?id=758949 Reopening of assessment under section 147 was held impermissible where the Assessing Officer lacked fresh and tangible material and relied on a mere change of opinion; the court applied the Kelvinator test and confirmed that information suggesting escaped income and prior approval of the specified authority are preconditions to valid notice. The decision emphasised that a pre reopening enquiry with opportunity to be heard and reply is required and time limits for reassessment must be met. For absence of requisite material and approvals, the reassessment proceedings were quashed by the High Court. en-us Fri, 23 Aug 2024 00:00:00 +0530 Mon, 09 Feb 2026 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758949 Reopening of assessment under section 147 was held impermissible where the Assessing Officer lacked fresh and tangible material and relied on a mere change of opinion; the court applied the Kelvinator test and confirmed that information suggesting escaped income and prior approval of the specified authority are preconditions to valid notice. The decision emphasised that a pre reopening enquiry with opportunity to be heard and reply is required and time limits for reassessment must be met. For absence of requisite material and approvals, the reassessment proceedings were quashed by the High Court. Case-Laws Income Tax Fri, 23 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758949