https://www.taxtmi.com/caselaws?id=470604 Reassessment under Section 147 cannot rest solely on tax-audit disclosures concerning Section 14A disallowance when the same issue was specifically examined and accepted in the original scrutiny assessment. The assessing officer had sought and accepted the taxpayer's explanation that no significant expenditure was incurred to earn exempt income and that investments came from personal funds. Reopening on the identical audit-report material, without subsequently received material, amounted to an impermissible review of an earlier assessment. Any inadequacy in the original enquiry could instead be addressed through revisionary jurisdiction. The reassessment notice, consequential reassessment order, and disallowance were treated as void. en-us Mon, 24 Mar 2025 00:00:00 +0530 Fri, 31 Jul 2026 19:03:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470604 Reassessment under Section 147 cannot rest solely on tax-audit disclosures concerning Section 14A disallowance when the same issue was specifically examined and accepted in the original scrutiny assessment. The assessing officer had sought and accepted the taxpayer's explanation that no significant expenditure was incurred to earn exempt income and that investments came from personal funds. Reopening on the identical audit-report material, without subsequently received material, amounted to an impermissible review of an earlier assessment. Any inadequacy in the original enquiry could instead be addressed through revisionary jurisdiction. The reassessment notice, consequential reassessment order, and disallowance were treated as void. Case-Laws Income Tax Mon, 24 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470604