https://www.taxtmi.com/caselaws?id=798483 Reassessment under Sections 147 and 148 cannot rest on information and statements already available and considered in earlier search assessment and revision proceedings. Where an investigation-wing communication merely repackages existing material, it does not provide fresh tangible material for reopening. Failure to address confirmations obtained from the concerned entities before issuing the reopening notice further supports that the action is based on a change of opinion. Approval founded solely on the same old statement, without independent consideration, is mechanical. Such reopening is beyond jurisdiction, requiring deletion of additions made in the reassessment. en-us Mon, 24 Aug 2026 00:00:00 +0530 Tue, 08 Sep 2026 08:42:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798483 Reassessment under Sections 147 and 148 cannot rest on information and statements already available and considered in earlier search assessment and revision proceedings. Where an investigation-wing communication merely repackages existing material, it does not provide fresh tangible material for reopening. Failure to address confirmations obtained from the concerned entities before issuing the reopening notice further supports that the action is based on a change of opinion. Approval founded solely on the same old statement, without independent consideration, is mechanical. Such reopening is beyond jurisdiction, requiring deletion of additions made in the reassessment. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798483