https://www.taxtmi.com/caselaws?id=797962 Reopening under Section 148 is impermissible where it merely reflects a genuine change of opinion on material examined in the original assessment. A licensing-related ground not considered during the original assessment does not constitute such a change of opinion, so reassessment may proceed. Advances made through negotiable instruments fall outside the licensing requirement under the Rajasthan Money Lending Act, 1963, but the exemption requires specific supporting particulars and proof that the material was previously supplied to the Assessing Officer. The reopening notice and rejection of objections were sustained, subject to verification of the instrument particulars by the Assessing Officer. en-us Tue, 14 Jul 2026 00:00:00 +0530 Mon, 31 Aug 2026 08:28:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797962 Reopening under Section 148 is impermissible where it merely reflects a genuine change of opinion on material examined in the original assessment. A licensing-related ground not considered during the original assessment does not constitute such a change of opinion, so reassessment may proceed. Advances made through negotiable instruments fall outside the licensing requirement under the Rajasthan Money Lending Act, 1963, but the exemption requires specific supporting particulars and proof that the material was previously supplied to the Assessing Officer. The reopening notice and rejection of objections were sustained, subject to verification of the instrument particulars by the Assessing Officer. Case-Laws Income Tax Tue, 14 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797962