https://www.taxtmi.com/caselaws?id=776991 ITAT held the reopening under s.147 invalid, finding the AO's "reasons to believe" were based on material already supplied by the assessee during the original s.143(3) assessment and therefore amounted to a mere change of opinion. As no fresh material or facts supported reopening and pre-conditions of the first proviso to s.147 were not met, the reassessment was quashed and decision rendered for the assessee. en-us Tue, 12 Aug 2025 00:00:00 +0530 Fri, 22 Aug 2025 08:33:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776991 ITAT held the reopening under s.147 invalid, finding the AO's "reasons to believe" were based on material already supplied by the assessee during the original s.143(3) assessment and therefore amounted to a mere change of opinion. As no fresh material or facts supported reopening and pre-conditions of the first proviso to s.147 were not met, the reassessment was quashed and decision rendered for the assessee. Case-Laws Income Tax Tue, 12 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776991