https://www.taxtmi.com/caselaws?id=466802 Reopening a completed scrutiny assessment requires tangible or relevant material on which a reasonable person could form the requisite belief that income escaped assessment; absent such material, issuance of a reopening notice constitutes an impermissible change of opinion rather than lawful reassessment. Where primary records, ledger accounts, audit report and detailed responses were placed on record during scrutiny and no additional tangible material emerged thereafter, the alleged omissions by the assessing officer did not supply the missing material basis for reopening; accordingly the reopening notice was quashed in favour of the assessee. en-us Mon, 31 Jul 2023 00:00:00 +0530 Fri, 20 Feb 2026 08:22:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466802 Reopening a completed scrutiny assessment requires tangible or relevant material on which a reasonable person could form the requisite belief that income escaped assessment; absent such material, issuance of a reopening notice constitutes an impermissible change of opinion rather than lawful reassessment. Where primary records, ledger accounts, audit report and detailed responses were placed on record during scrutiny and no additional tangible material emerged thereafter, the alleged omissions by the assessing officer did not supply the missing material basis for reopening; accordingly the reopening notice was quashed in favour of the assessee. Case-Laws Income Tax Mon, 31 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466802