https://www.taxtmi.com/caselaws?id=791414 Reassessment under the Income-tax Act cannot be sustained where the reopening rests on the same material already examined and finally adjudicated in earlier proceedings. The assessee's TDS credit and the underlying interest income had already been considered in the appellate order, and the sanction note relied only on figures from the Insight Portal and the existing record without any fresh tangible information or independent basis for escapement. In the absence of new material, the notice under Section 148 was founded on a mere change of opinion and failed the jurisdictional requirement for reopening. The notice and connected sanction note were therefore invalid and liable to be set aside. en-us Fri, 01 May 2026 00:00:00 +0530 Mon, 11 May 2026 09:50:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791414 Reassessment under the Income-tax Act cannot be sustained where the reopening rests on the same material already examined and finally adjudicated in earlier proceedings. The assessee's TDS credit and the underlying interest income had already been considered in the appellate order, and the sanction note relied only on figures from the Insight Portal and the existing record without any fresh tangible information or independent basis for escapement. In the absence of new material, the notice under Section 148 was founded on a mere change of opinion and failed the jurisdictional requirement for reopening. The notice and connected sanction note were therefore invalid and liable to be set aside. Case-Laws Income Tax Fri, 01 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791414