https://www.taxtmi.com/highlights?id=99650 Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings. en-us Mon, 11 May 2026 09:50:58 +0530 Mon, 11 May 2026 09:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99650 Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings. Highlights Income Tax Mon, 11 May 2026 09:50:58 +0530 https://www.taxtmi.com/highlights?id=99650