https://www.taxtmi.com/caselaws?id=782727 The ITAT Delhi allowed the assessee's appeal, quashing the reassessment initiated u/s 147/148. It held that a regular assessment u/s 143(3) had already been completed after the AO specifically raised a query on the impugned issue and accepted the assessee's submissions. In the absence of any new tangible material, the subsequent "reasons to believe" were found to be a mere review of the earlier order, barred as a "change of opinion." Relying on binding precedent, the Tribunal ruled that the AO lacks jurisdiction to reopen a concluded assessment solely because the issue was not expressly discussed in the original order. en-us Thu, 30 Oct 2025 00:00:00 +0530 Wed, 03 Dec 2025 08:57:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782727 The ITAT Delhi allowed the assessee's appeal, quashing the reassessment initiated u/s 147/148. It held that a regular assessment u/s 143(3) had already been completed after the AO specifically raised a query on the impugned issue and accepted the assessee's submissions. In the absence of any new tangible material, the subsequent "reasons to believe" were found to be a mere review of the earlier order, barred as a "change of opinion." Relying on binding precedent, the Tribunal ruled that the AO lacks jurisdiction to reopen a concluded assessment solely because the issue was not expressly discussed in the original order. Case-Laws Income Tax Thu, 30 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782727