https://www.taxtmi.com/caselaws?id=785671 Reopening of assessment under section 147 on a change-of-opinion basis remained impermissible where the reassessment notice concerned lease payments, foreign currency transactions, and depreciation on goodwill. The Gujarat High Court quashed the section 148 notice, and the Supreme Court found no reason to interfere, leaving that order undisturbed. The matter reflects the settled constraint that reassessment cannot be used to revisit issues already examined merely because the assessing authority has changed its view. en-us Tue, 27 Jan 2026 00:00:00 +0530 Tue, 14 Jul 2026 16:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785671 Reopening of assessment under section 147 on a change-of-opinion basis remained impermissible where the reassessment notice concerned lease payments, foreign currency transactions, and depreciation on goodwill. The Gujarat High Court quashed the section 148 notice, and the Supreme Court found no reason to interfere, leaving that order undisturbed. The matter reflects the settled constraint that reassessment cannot be used to revisit issues already examined merely because the assessing authority has changed its view. Case-Laws Income Tax Tue, 27 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785671