https://www.taxtmi.com/caselaws?id=460724 A reopening under section 147 must rest on a valid reason to believe that income has escaped assessment, even where the original assessment was accepted without scrutiny and the change of opinion doctrine does not apply. Here, the assessee had replied to the cash-deposit query and supported the source with material, but the recorded reasons incorrectly stated that no explanation had been furnished. A belief based on that ? no, English. A belief based on incorrect facts could not sustain reopening, and the notice could not be saved by later improving the recorded reasons. The reopening notice was invalid and was quashed. en-us Mon, 19 Mar 2018 00:00:00 +0530 Wed, 12 Feb 2025 19:00:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460724 A reopening under section 147 must rest on a valid reason to believe that income has escaped assessment, even where the original assessment was accepted without scrutiny and the change of opinion doctrine does not apply. Here, the assessee had replied to the cash-deposit query and supported the source with material, but the recorded reasons incorrectly stated that no explanation had been furnished. A belief based on that ? no, English. A belief based on incorrect facts could not sustain reopening, and the notice could not be saved by later improving the recorded reasons. The reopening notice was invalid and was quashed. Case-Laws Income Tax Mon, 19 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460724