https://www.taxtmi.com/caselaws?id=787167 Reopening of assessment under section 147 was challenged on the ground of change of opinion, audit objection, and absence of failure to disclose material facts where the original scrutiny assessment was under section 143(3) and the notice was issued after four years. The text states that mere reconsideration of a deduction cannot confer jurisdiction to reopen in such circumstances, and that the reasons must have a proper link with the evidence relied on. It further records that the Special Leave Petition was filed with a 124-day delay, for which no bona fide explanation was found, and the Supreme Court declined interference on both delay and merits. en-us Mon, 23 Feb 2026 00:00:00 +0530 Tue, 14 Jul 2026 16:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787167 Reopening of assessment under section 147 was challenged on the ground of change of opinion, audit objection, and absence of failure to disclose material facts where the original scrutiny assessment was under section 143(3) and the notice was issued after four years. The text states that mere reconsideration of a deduction cannot confer jurisdiction to reopen in such circumstances, and that the reasons must have a proper link with the evidence relied on. It further records that the Special Leave Petition was filed with a 124-day delay, for which no bona fide explanation was found, and the Supreme Court declined interference on both delay and merits. Case-Laws Income Tax Mon, 23 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787167