https://www.taxtmi.com/caselaws?id=791405 Reassessment under sections 147 and 148 was invalid where the reopening was based only on a Revenue audit objection and material already examined in the original scrutiny assessment under section 143(3). The recorded reasons showed no fresh tangible material or independent satisfaction; reopening on the same facts amounted to a mere change of opinion. The statutory requirement of reason to believe was therefore not met, as an audit objection cannot replace the assessing authority's own quasi-judicial satisfaction. The reassessment notice was quashed and the reassessment order was set aside in favour of the assessee. en-us Fri, 08 May 2026 00:00:00 +0530 Mon, 11 May 2026 09:50:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791405 Reassessment under sections 147 and 148 was invalid where the reopening was based only on a Revenue audit objection and material already examined in the original scrutiny assessment under section 143(3). The recorded reasons showed no fresh tangible material or independent satisfaction; reopening on the same facts amounted to a mere change of opinion. The statutory requirement of reason to believe was therefore not met, as an audit objection cannot replace the assessing authority's own quasi-judicial satisfaction. The reassessment notice was quashed and the reassessment order was set aside in favour of the assessee. Case-Laws Income Tax Fri, 08 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791405