https://www.taxtmi.com/caselaws?id=767216 The Karnataka HC held that reassessment proceedings under Section 147 were invalid as they were based on a mere change of opinion rather than tangible material indicating escaped income. The AO had already assessed the same material during original assessment and reduced Section 10A deductions accordingly. Since no new material or undisclosed income was identified, and the assessee had made true and full disclosure of primary facts, the reopening was impermissible. The court emphasized that reconsideration of previously assessed material without fresh evidence does not justify reassessment proceedings. en-us Mon, 24 Feb 2025 00:00:00 +0530 Wed, 12 Mar 2025 09:06:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767216 The Karnataka HC held that reassessment proceedings under Section 147 were invalid as they were based on a mere change of opinion rather than tangible material indicating escaped income. The AO had already assessed the same material during original assessment and reduced Section 10A deductions accordingly. Since no new material or undisclosed income was identified, and the assessee had made true and full disclosure of primary facts, the reopening was impermissible. The court emphasized that reconsideration of previously assessed material without fresh evidence does not justify reassessment proceedings. Case-Laws Income Tax Mon, 24 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767216