https://www.taxtmi.com/caselaws?id=783139 HC quashed the reassessment proceedings initiated against the petitioner for AY 2019-20 under s.148. It held that the AO was impermissibly attempting a "change of opinion" on the same transactions, between the same parties, based on the identical search/seizure material earlier used to reassess the transporter's income for the same year. Having already accepted both parties' denial of cash return while completing the transporter's reassessment, the AO could not review that conclusion indirectly through reopening the petitioner's assessment. Such a reassessment on the same point amounted to a prohibited review, rendering the notice and proceedings without jurisdiction. en-us Mon, 08 Dec 2025 00:00:00 +0530 Wed, 10 Dec 2025 08:41:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783139 HC quashed the reassessment proceedings initiated against the petitioner for AY 2019-20 under s.148. It held that the AO was impermissibly attempting a "change of opinion" on the same transactions, between the same parties, based on the identical search/seizure material earlier used to reassess the transporter's income for the same year. Having already accepted both parties' denial of cash return while completing the transporter's reassessment, the AO could not review that conclusion indirectly through reopening the petitioner's assessment. Such a reassessment on the same point amounted to a prohibited review, rendering the notice and proceedings without jurisdiction. Case-Laws Income Tax Mon, 08 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783139