https://www.taxtmi.com/caselaws?id=759036 Gujarat HC held that reopening assessment under Section 147 based on same facts previously examined during scrutiny constitutes impermissible change of opinion. The petitioner had already furnished complete details regarding immovable property transactions and Section 54F deduction claim with supporting evidence during original assessment. Since no new information or tangible material emerged, the AO's attempt to reopen assessment on identical grounds was deemed arbitrary. The court distinguished between power to review versus reassess, emphasizing that reassessment requires fulfillment of pre-conditions and cannot be based on mere change of opinion. The petition was decided in favor of the assessee. en-us Tue, 17 Sep 2024 00:00:00 +0530 Mon, 23 Sep 2024 09:10:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759036 Gujarat HC held that reopening assessment under Section 147 based on same facts previously examined during scrutiny constitutes impermissible change of opinion. The petitioner had already furnished complete details regarding immovable property transactions and Section 54F deduction claim with supporting evidence during original assessment. Since no new information or tangible material emerged, the AO's attempt to reopen assessment on identical grounds was deemed arbitrary. The court distinguished between power to review versus reassess, emphasizing that reassessment requires fulfillment of pre-conditions and cannot be based on mere change of opinion. The petition was decided in favor of the assessee. Case-Laws Income Tax Tue, 17 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759036