https://www.taxtmi.com/caselaws?id=786666 Reopening of income-tax assessments on the sole basis of an audit party's objection that presents only a different opinion on facts already considered is impermissible; the statutory test for reopening requires the Assessing Officer to have his own reasoned 'reason to believe' that income has escaped assessment, based on new or overlooked factual material. Where the audit objection points to a previously undiscovered factual omission, reassessment may follow provided the AO independently forms a reasoned satisfaction; where it merely reflects a contrary view on the same material, it amounts to change of opinion and cannot sustain reassessment. en-us Mon, 09 Feb 2026 00:00:00 +0530 Tue, 17 Feb 2026 07:29:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786666 Reopening of income-tax assessments on the sole basis of an audit party's objection that presents only a different opinion on facts already considered is impermissible; the statutory test for reopening requires the Assessing Officer to have his own reasoned 'reason to believe' that income has escaped assessment, based on new or overlooked factual material. Where the audit objection points to a previously undiscovered factual omission, reassessment may follow provided the AO independently forms a reasoned satisfaction; where it merely reflects a contrary view on the same material, it amounts to change of opinion and cannot sustain reassessment. Case-Laws Income Tax Mon, 09 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786666