https://www.taxtmi.com/caselaws?id=460708 A reopening notice under section 148 was prima facie vulnerable to challenge where the same warranty provision had already been specifically queried during the original section 143(3) assessment. The assessment record showed that the Assessing Officer sought details of the provision's basis, opening balance, actual payments and comparative figures, and the assessee replied before the assessment was completed without disallowance. On those facts, the proposed reopening was based on a matter already examined, supporting a change-of-opinion objection. Authority dealing with cases where no such query had been raised was distinguished on that basis, and interim relief was granted in terms of prayer clause (D). en-us Wed, 04 May 2016 00:00:00 +0530 Tue, 11 Feb 2025 21:16:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460708 A reopening notice under section 148 was prima facie vulnerable to challenge where the same warranty provision had already been specifically queried during the original section 143(3) assessment. The assessment record showed that the Assessing Officer sought details of the provision's basis, opening balance, actual payments and comparative figures, and the assessee replied before the assessment was completed without disallowance. On those facts, the proposed reopening was based on a matter already examined, supporting a change-of-opinion objection. Authority dealing with cases where no such query had been raised was distinguished on that basis, and interim relief was granted in terms of prayer clause (D). Case-Laws Income Tax Wed, 04 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460708