https://www.taxtmi.com/caselaws?id=792509 Reassessment under section 147 was held invalid because it was initiated on the same material already examined in the original section 143(3) assessment, without any fresh tangible material, and on an incorrect factual assumption that the R&D account had not been separately furnished. The reopening was therefore treated as a change of opinion and the assumption of jurisdiction failed. On merits, the disallowance of depreciation included in research and development expenses was deleted because the amount had already been added back in computation and there was no basis for a separate disallowance or multiple deduction concern. en-us Tue, 26 May 2026 00:00:00 +0530 Fri, 29 May 2026 08:59:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792509 Reassessment under section 147 was held invalid because it was initiated on the same material already examined in the original section 143(3) assessment, without any fresh tangible material, and on an incorrect factual assumption that the R&D account had not been separately furnished. The reopening was therefore treated as a change of opinion and the assumption of jurisdiction failed. On merits, the disallowance of depreciation included in research and development expenses was deleted because the amount had already been added back in computation and there was no basis for a separate disallowance or multiple deduction concern. Case-Laws Income Tax Tue, 26 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792509