https://www.taxtmi.com/caselaws?id=766027 Reopening under section 148 was invalid where the original assessment under section 143(3) had already examined the same material and the reasons for reassessment relied only on audit objections and the same profit and loss account entries. No fresh tangible material or independent information supported a new belief that expenditure required disallowance. The reopening was therefore a mere change of opinion on concluded issues, which is impermissible. The notice under section 148 was quashed in favour of the assessee. en-us Wed, 12 Feb 2025 00:00:00 +0530 Sat, 15 Feb 2025 08:00:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766027 Reopening under section 148 was invalid where the original assessment under section 143(3) had already examined the same material and the reasons for reassessment relied only on audit objections and the same profit and loss account entries. No fresh tangible material or independent information supported a new belief that expenditure required disallowance. The reopening was therefore a mere change of opinion on concluded issues, which is impermissible. The notice under section 148 was quashed in favour of the assessee. Case-Laws Income Tax Wed, 12 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766027