https://www.taxtmi.com/highlights?id=102882 Reopening after four years requires fresh tangible material and satisfaction of the proviso to section 147; a reassessment cannot rest on a mere change of opinion. Audit objections led the Assessing Officer to re-examine balance-sheet documents and records already available during the original assessment, without new evidence or information indicating escaped income. The Tribunal quashed the reassessment for lack of jurisdiction. High Court found no substantial question of law, affirming that the Assessing Officer could not reopen the assessment solely through reappraisal of existing material beyond the four-year period. en-us Thu, 20 Aug 2026 08:14:28 +0530 Thu, 20 Aug 2026 08:14:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102882 Reopening after four years requires fresh tangible material and satisfaction of the proviso to section 147; a reassessment cannot rest on a mere change of opinion. Audit objections led the Assessing Officer to re-examine balance-sheet documents and records already available during the original assessment, without new evidence or information indicating escaped income. The Tribunal quashed the reassessment for lack of jurisdiction. High Court found no substantial question of law, affirming that the Assessing Officer could not reopen the assessment solely through reappraisal of existing material beyond the four-year period. Highlights Income Tax Thu, 20 Aug 2026 08:14:28 +0530 https://www.taxtmi.com/highlights?id=102882