https://www.taxtmi.com/caselaws?id=789256 Reopening under section 147 was invalid where the original assessment had been completed under section 143(3), the alleged escapement was based on the same material already examined, and no fresh tangible material supported a new reason to believe. The Tribunal treated the reassessment as a mere change of opinion and noted that earlier rectification proceedings under section 154 had been withdrawn on the same basis, reinforcing the absence of a valid jurisdictional foundation. The reassessment notice was therefore held bad in law, and the addition did not survive. en-us Thu, 26 Feb 2026 00:00:00 +0530 Mon, 06 Apr 2026 08:51:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789256 Reopening under section 147 was invalid where the original assessment had been completed under section 143(3), the alleged escapement was based on the same material already examined, and no fresh tangible material supported a new reason to believe. The Tribunal treated the reassessment as a mere change of opinion and noted that earlier rectification proceedings under section 154 had been withdrawn on the same basis, reinforcing the absence of a valid jurisdictional foundation. The reassessment notice was therefore held bad in law, and the addition did not survive. Case-Laws Income Tax Thu, 26 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789256