https://www.taxtmi.com/caselaws?id=40358 The dominant issue was the validity of a reassessment notice under ss. 147/148, where the reopening sought to reassess taxability of income alleged to accrue or be deemed to accrue in India in the context of a DTAA. The HC held that the Tribunal, while deciding the assessee's appeal, had already examined the same material and relied on its earlier decision in a comparable case; the proposed reopening therefore amounted to a mere change of opinion, impermissible under s. 147, rendering the notice illegal. The SC found no reason to interfere and dismissed the revenue's civil appeals with costs. en-us Thu, 16 Jan 2003 00:00:00 +0530 Fri, 26 Dec 2025 15:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=40358 The dominant issue was the validity of a reassessment notice under ss. 147/148, where the reopening sought to reassess taxability of income alleged to accrue or be deemed to accrue in India in the context of a DTAA. The HC held that the Tribunal, while deciding the assessee's appeal, had already examined the same material and relied on its earlier decision in a comparable case; the proposed reopening therefore amounted to a mere change of opinion, impermissible under s. 147, rendering the notice illegal. The SC found no reason to interfere and dismissed the revenue's civil appeals with costs. Case-Laws Income Tax Thu, 16 Jan 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=40358