https://www.taxtmi.com/caselaws?id=790408 Reopening of a completed scrutiny assessment is impermissible when it is based only on a reappraisal of material already examined in the original proceedings. The assessment under section 143(3) had considered the books, trading results, bank statements, debtors and creditors, and no adverse finding was made on sales suppression or milk purchase price. As the reassessment relied on the same material and a fresh estimate of average milk price without new tangible evidence, it amounted to a mere change of opinion. The reopening was therefore held invalid. en-us Tue, 21 Apr 2026 00:00:00 +0530 Fri, 24 Apr 2026 08:52:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790408 Reopening of a completed scrutiny assessment is impermissible when it is based only on a reappraisal of material already examined in the original proceedings. The assessment under section 143(3) had considered the books, trading results, bank statements, debtors and creditors, and no adverse finding was made on sales suppression or milk purchase price. As the reassessment relied on the same material and a fresh estimate of average milk price without new tangible evidence, it amounted to a mere change of opinion. The reopening was therefore held invalid. Case-Laws Income Tax Tue, 21 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790408