https://www.taxtmi.com/caselaws?id=465813 Reopening of assessment under s.147 was challenged on the ground that the AO lacked "reasons to believe" supported by tangible material. The HC held that even where the original assessment was processed without scrutiny, reopening requires fresh tangible material; a mere reappraisal of the same claim for deduction under s.80CCC is impermissible. Further, since an identical issue in the related assessee's case had already been examined in scrutiny, initiation of reassessment on the same basis was barred as a change of opinion. The reassessment notice was therefore quashed and the writ petition was allowed. en-us Tue, 29 Aug 2023 00:00:00 +0530 Fri, 09 Jan 2026 19:03:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465813 Reopening of assessment under s.147 was challenged on the ground that the AO lacked "reasons to believe" supported by tangible material. The HC held that even where the original assessment was processed without scrutiny, reopening requires fresh tangible material; a mere reappraisal of the same claim for deduction under s.80CCC is impermissible. Further, since an identical issue in the related assessee's case had already been examined in scrutiny, initiation of reassessment on the same basis was barred as a change of opinion. The reassessment notice was therefore quashed and the writ petition was allowed. Case-Laws Income Tax Tue, 29 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465813