https://www.taxtmi.com/caselaws?id=790317 Reassessment under section 147 was invalid because it was based on material already examined in the original assessment and not on new tangible material showing escapement of income. The Tribunal noted that the acquisition date and capital gains treatment of the property transaction had already been considered, so the reopening amounted to a mere change of opinion. In the absence of any failure by the assessee to disclose fully and truly all material facts, the statutory conditions for invoking reassessment jurisdiction were not met. The reassessment notice and consequent assessment were therefore held unsustainable and were set aside. en-us Fri, 17 Apr 2026 00:00:00 +0530 Thu, 23 Apr 2026 09:45:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790317 Reassessment under section 147 was invalid because it was based on material already examined in the original assessment and not on new tangible material showing escapement of income. The Tribunal noted that the acquisition date and capital gains treatment of the property transaction had already been considered, so the reopening amounted to a mere change of opinion. In the absence of any failure by the assessee to disclose fully and truly all material facts, the statutory conditions for invoking reassessment jurisdiction were not met. The reassessment notice and consequent assessment were therefore held unsustainable and were set aside. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790317