https://www.taxtmi.com/caselaws?id=794515 Reassessment under section 147 was treated as invalid where the cash-deposit issue had already been examined in the original section 143(3) assessment on the same material; reopening on that basis was characterised as a mere change of opinion and annulled. The addition made in reassessment also failed because the assessee was not given a reasonable opportunity: the notice-to-order gap was very short, the reply was rejected without identifying the further evidence required, and the procedure was found unfair. The reassessment was annulled and the substantive addition was deleted. en-us Tue, 09 Jun 2026 00:00:00 +0530 Tue, 07 Jul 2026 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794515 Reassessment under section 147 was treated as invalid where the cash-deposit issue had already been examined in the original section 143(3) assessment on the same material; reopening on that basis was characterised as a mere change of opinion and annulled. The addition made in reassessment also failed because the assessee was not given a reasonable opportunity: the notice-to-order gap was very short, the reply was rejected without identifying the further evidence required, and the procedure was found unfair. The reassessment was annulled and the substantive addition was deleted. Case-Laws Income Tax Tue, 09 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794515