https://www.taxtmi.com/caselaws?id=460709 Reassessment under Section 148 was impermissible where the Assessing Officer had already raised a specific query on the warranty provision during the original Section 143(3) assessment, called for information, and received a reply. The issue was therefore treated as having been examined in the original proceedings, even though the assessment order did not expressly discuss it. Reopening on the same material amounted to a mere change of opinion and could not supply the requisite reason to believe that income had escaped assessment. The reassessment notice was quashed in favour of the assessee. en-us Thu, 07 Mar 2024 00:00:00 +0530 Tue, 11 Feb 2025 21:16:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460709 Reassessment under Section 148 was impermissible where the Assessing Officer had already raised a specific query on the warranty provision during the original Section 143(3) assessment, called for information, and received a reply. The issue was therefore treated as having been examined in the original proceedings, even though the assessment order did not expressly discuss it. Reopening on the same material amounted to a mere change of opinion and could not supply the requisite reason to believe that income had escaped assessment. The reassessment notice was quashed in favour of the assessee. Case-Laws Income Tax Thu, 07 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460709