https://www.taxtmi.com/caselaws?id=792437 Reopening based on the same facts and material already examined by the appellate authority was treated as a re-examination of a concluded issue, not as a case arising from fresh information. The Rajasthan HC held that the absence of new material meant the reassessment action reflected a change of opinion and was beyond jurisdiction. The notice issued under Section 148, the sanction note founded on that same material, and all consequential proceedings were set aside. en-us Thu, 21 May 2026 00:00:00 +0530 Thu, 28 May 2026 08:21:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792437 Reopening based on the same facts and material already examined by the appellate authority was treated as a re-examination of a concluded issue, not as a case arising from fresh information. The Rajasthan HC held that the absence of new material meant the reassessment action reflected a change of opinion and was beyond jurisdiction. The notice issued under Section 148, the sanction note founded on that same material, and all consequential proceedings were set aside. Case-Laws Income Tax Thu, 21 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792437