https://www.taxtmi.com/highlights?id=101134 Reassessment within four years still required a live basis for "reason to believe"; the Court held that reopening cannot rest on a mere review of a concluded scrutiny assessment. Where the assessee had already replied to queries and furnished supporting material, those issues were treated as examined even if not expressly discussed in the assessment order. The reopening on deductions and depreciation claims was therefore a change of opinion, and the only asserted fresh basis, an audit objection, was not tangible material. The notice under Section 148 and the order rejecting objections were quashed as beyond jurisdiction. en-us Fri, 26 Jun 2026 07:07:29 +0530 Fri, 26 Jun 2026 07:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101134 Reassessment within four years still required a live basis for "reason to believe"; the Court held that reopening cannot rest on a mere review of a concluded scrutiny assessment. Where the assessee had already replied to queries and furnished supporting material, those issues were treated as examined even if not expressly discussed in the assessment order. The reopening on deductions and depreciation claims was therefore a change of opinion, and the only asserted fresh basis, an audit objection, was not tangible material. The notice under Section 148 and the order rejecting objections were quashed as beyond jurisdiction. Highlights Income Tax Fri, 26 Jun 2026 07:07:29 +0530 https://www.taxtmi.com/highlights?id=101134