https://www.taxtmi.com/caselaws?id=468841 Reassessment under section 147 is not treated as a change of opinion where the original limited scrutiny assessment never examined the escaped-income issue, so the reassessment remains valid. Tax proceedings may also be initiated during the corporate insolvency resolution process, provided coercive recovery is not pursued in breach of the moratorium framework. For revision under section 263, where the revisional issue is independent of the reassessment order, limitation runs from the original assessment order; on that basis, an order passed beyond the prescribed period is time-barred. en-us Tue, 11 Feb 2025 00:00:00 +0530 Fri, 22 May 2026 10:22:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468841 Reassessment under section 147 is not treated as a change of opinion where the original limited scrutiny assessment never examined the escaped-income issue, so the reassessment remains valid. Tax proceedings may also be initiated during the corporate insolvency resolution process, provided coercive recovery is not pursued in breach of the moratorium framework. For revision under section 263, where the revisional issue is independent of the reassessment order, limitation runs from the original assessment order; on that basis, an order passed beyond the prescribed period is time-barred. Case-Laws Income Tax Tue, 11 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468841