https://www.taxtmi.com/caselaws?id=462895 Reassessment was invalid where the reopening rested only on material already examined in the original assessment and no fresh tangible material was shown to justify a belief of escapement of income. The recorded reasons relied on the existing assessment record, including foreign currency translation reserve and interest accrued but not due, so the attempt amounted to an impermissible change of opinion rather than a lawful reassessment. As the reassessment lacked jurisdiction, the additions made pursuant to it were not adjudicated on merits and were treated as academic. The assessee's appeals were allowed and the Revenue's appeal failed. en-us Thu, 11 Jul 2024 00:00:00 +0530 Wed, 23 Jul 2025 20:31:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462895 Reassessment was invalid where the reopening rested only on material already examined in the original assessment and no fresh tangible material was shown to justify a belief of escapement of income. The recorded reasons relied on the existing assessment record, including foreign currency translation reserve and interest accrued but not due, so the attempt amounted to an impermissible change of opinion rather than a lawful reassessment. As the reassessment lacked jurisdiction, the additions made pursuant to it were not adjudicated on merits and were treated as academic. The assessee's appeals were allowed and the Revenue's appeal failed. Case-Laws Income Tax Thu, 11 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462895