https://www.taxtmi.com/caselaws?id=470170 Reopening of a completed assessment requires a reason to believe that taxable income escaped assessment based on tangible material and cannot be used to review an earlier view. The assessment record of an association of persons contained a detailed finding that the assessee's entitlement to 35% of gross sale proceeds represented revenue sharing for surrendered development rights rather than a share of profits. As that material was not considered in the assessee's original assessment and differed from the earlier year's record, the reopening was within jurisdiction and did not constitute a change of opinion. en-us Mon, 19 Dec 2011 00:00:00 +0530 Sat, 18 Jul 2026 11:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470170 Reopening of a completed assessment requires a reason to believe that taxable income escaped assessment based on tangible material and cannot be used to review an earlier view. The assessment record of an association of persons contained a detailed finding that the assessee's entitlement to 35% of gross sale proceeds represented revenue sharing for surrendered development rights rather than a share of profits. As that material was not considered in the assessee's original assessment and differed from the earlier year's record, the reopening was within jurisdiction and did not constitute a change of opinion. Case-Laws Income Tax Mon, 19 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470170