https://www.taxtmi.com/caselaws?id=798978 Reassessment following a completed scrutiny assessment is invalid where it revisits a share-sale transaction, valuation, purchaser credibility, genuineness and capital-gains exemption already examined and accepted after detailed inquiry. An assessment order need not record every query or reasons for accepting a claim; inquiry and acceptance establish formation of opinion. Reopening on the same material therefore constitutes a change of opinion. A new objection to an exemption claim that was not stated in the show-cause notice cannot support reopening, and recorded reasons cannot be supplemented through an affidavit or oral submissions. The reassessment notices and consequential proceedings were quashed. en-us Tue, 08 Sep 2026 00:00:00 +0530 Tue, 15 Sep 2026 08:31:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798978 Reassessment following a completed scrutiny assessment is invalid where it revisits a share-sale transaction, valuation, purchaser credibility, genuineness and capital-gains exemption already examined and accepted after detailed inquiry. An assessment order need not record every query or reasons for accepting a claim; inquiry and acceptance establish formation of opinion. Reopening on the same material therefore constitutes a change of opinion. A new objection to an exemption claim that was not stated in the show-cause notice cannot support reopening, and recorded reasons cannot be supplemented through an affidavit or oral submissions. The reassessment notices and consequential proceedings were quashed. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798978