https://www.taxtmi.com/caselaws?id=789495 Second reassessment under section 147 was held without jurisdiction because it relied on the same investigation material, alleged accommodation-entry information, parties and purchase figures already examined in the earlier reassessment. In the absence of any fresh tangible material, section 147 could not be used to review an earlier conclusion on identical facts. As the issue had already been adjudicated through the appellate hierarchy and had attained finality, the provisory restrictions to section 147 barred reopening the same matter again. The allegation of failure to disclose fully and truly all material facts also failed because the basis of reopening had already been available and considered earlier. en-us Tue, 07 Apr 2026 00:00:00 +0530 Thu, 09 Apr 2026 08:09:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789495 Second reassessment under section 147 was held without jurisdiction because it relied on the same investigation material, alleged accommodation-entry information, parties and purchase figures already examined in the earlier reassessment. In the absence of any fresh tangible material, section 147 could not be used to review an earlier conclusion on identical facts. As the issue had already been adjudicated through the appellate hierarchy and had attained finality, the provisory restrictions to section 147 barred reopening the same matter again. The allegation of failure to disclose fully and truly all material facts also failed because the basis of reopening had already been available and considered earlier. Case-Laws Income Tax Tue, 07 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789495