https://www.taxtmi.com/caselaws?id=471127 Reassessment under Section 148 cannot rest on a different view of material already examined in the original scrutiny assessment. Where additions to fixed assets, borrowings, interest payments and capital work-in-progress had been scrutinised, including disallowance of interest and the proviso to Section 36(1)(iii), reopening based solely on the same balance-sheet material amounts to an impermissible change of opinion. In the absence of subsequent tangible information indicating escaped income, the reassessment initiation was invalid and quashed in favour of the assessee. en-us Wed, 02 Apr 2025 00:00:00 +0530 Fri, 21 Aug 2026 20:33:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471127 Reassessment under Section 148 cannot rest on a different view of material already examined in the original scrutiny assessment. Where additions to fixed assets, borrowings, interest payments and capital work-in-progress had been scrutinised, including disallowance of interest and the proviso to Section 36(1)(iii), reopening based solely on the same balance-sheet material amounts to an impermissible change of opinion. In the absence of subsequent tangible information indicating escaped income, the reassessment initiation was invalid and quashed in favour of the assessee. Case-Laws Income Tax Wed, 02 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471127