https://www.taxtmi.com/caselaws?id=468674 Reassessment under section 148 was held invalid where the original section 143(3) assessments had already examined the section 80JJAA deduction, Form 10DA, and manufacturing s. The Court found that later survey material based on a subsequent year's trial balance was not tangible material to reopen earlier completed assessments, and that comparing later unaudited figures with prior years did not create a lawful basis for reassessment. It also held that the objection about non-electronic filing of Form 10DA could not justify reopening, as the issue had not been raised in the original scrutiny proceedings and reopening on that ground amounted to a change of opinion. The notices and orders disposing of objections were set aside. en-us Thu, 06 Nov 2025 00:00:00 +0530 Fri, 15 May 2026 20:34:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468674 Reassessment under section 148 was held invalid where the original section 143(3) assessments had already examined the section 80JJAA deduction, Form 10DA, and manufacturing s. The Court found that later survey material based on a subsequent year's trial balance was not tangible material to reopen earlier completed assessments, and that comparing later unaudited figures with prior years did not create a lawful basis for reassessment. It also held that the objection about non-electronic filing of Form 10DA could not justify reopening, as the issue had not been raised in the original scrutiny proceedings and reopening on that ground amounted to a change of opinion. The notices and orders disposing of objections were set aside. Case-Laws Income Tax Thu, 06 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468674