https://www.taxtmi.com/caselaws?id=792962 Reassessment is not barred by change of opinion unless the original assessment shows a formed view on the specific issue; mere acceptance of a return is insufficient. Where later information provides tangible material indicating escapement of income, reopening is supportable. On the merits, income under the mercantile system is taxable on accrual, not receipt. Accordingly, where the record showed that interest had accrued in the relevant year and no material disproved accrual, the balance interest income was taxable in that year. A later-year finding required verification to avoid double taxation, but it did not override accrual-based taxability in the year of accrual. en-us Fri, 15 May 2026 00:00:00 +0530 Sat, 06 Jun 2026 08:42:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792962 Reassessment is not barred by change of opinion unless the original assessment shows a formed view on the specific issue; mere acceptance of a return is insufficient. Where later information provides tangible material indicating escapement of income, reopening is supportable. On the merits, income under the mercantile system is taxable on accrual, not receipt. Accordingly, where the record showed that interest had accrued in the relevant year and no material disproved accrual, the balance interest income was taxable in that year. A later-year finding required verification to avoid double taxation, but it did not override accrual-based taxability in the year of accrual. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792962