https://www.taxtmi.com/caselaws?id=784547 Reopening u/s 147 after four years was tested against the "change of opinion" bar. The Tribunal found that, in the original scrutiny, the AO had examined the books, audited financials, ledgers and vouchers for machinery rent, purchases and carriage, and had already applied his mind to cash payments and made an ad hoc disallowance; no fresh/tangible material emerged thereafter, so reopening was impermissible under SC law in Kelvinator. Consequently, the notice u/s 148 and reassessment were quashed. The alleged u/s 68 addition based on a ledger balance difference with a creditor was held to stem from a transparent accounting misposting of a bank transfer later rectified, with no impact on cash or overall liabilities; it could not justify reopening. Appeal allowed. en-us Mon, 05 Jan 2026 00:00:00 +0530 Wed, 07 Jan 2026 08:03:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784547 Reopening u/s 147 after four years was tested against the "change of opinion" bar. The Tribunal found that, in the original scrutiny, the AO had examined the books, audited financials, ledgers and vouchers for machinery rent, purchases and carriage, and had already applied his mind to cash payments and made an ad hoc disallowance; no fresh/tangible material emerged thereafter, so reopening was impermissible under SC law in Kelvinator. Consequently, the notice u/s 148 and reassessment were quashed. The alleged u/s 68 addition based on a ledger balance difference with a creditor was held to stem from a transparent accounting misposting of a bank transfer later rectified, with no impact on cash or overall liabilities; it could not justify reopening. Appeal allowed. Case-Laws Income Tax Mon, 05 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784547