https://www.taxtmi.com/caselaws?id=791704 Reassessment is invalid where the recorded reasons for reopening show no application of mind and the matters sought to be reopened were already examined in the original assessment, because reopening in such circumstances amounts to an impermissible change of opinion. The order disposing of objections must also specifically rebut the assessee's contentions; failure to do so weakens the reopening. In the present matter, the Special Leave Petition was dismissed for inordinate delay of 276 days, as no plausible and bona fide explanation was offered for condonation. en-us Mon, 11 May 2026 00:00:00 +0530 Fri, 15 May 2026 09:15:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791704 Reassessment is invalid where the recorded reasons for reopening show no application of mind and the matters sought to be reopened were already examined in the original assessment, because reopening in such circumstances amounts to an impermissible change of opinion. The order disposing of objections must also specifically rebut the assessee's contentions; failure to do so weakens the reopening. In the present matter, the Special Leave Petition was dismissed for inordinate delay of 276 days, as no plausible and bona fide explanation was offered for condonation. Case-Laws Income Tax Mon, 11 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791704