https://www.taxtmi.com/highlights?id=104221 Reassessment under Section 147 cannot be used to review conclusions reached in an original scrutiny assessment. Where the Assessing Officer had specifically examined depreciation claims, deductions, exempt-income expenditure and pre-production income, reopening based only on the same assessment record and a successor officer's different inference constitutes a change of opinion. In the absence of fresh tangible material, a false statement, or failure to make full and true disclosure of material facts, no jurisdictional reason to believe that income escaped assessment arises. The reassessment was therefore quashed and the revenue's appeal dismissed. en-us Sat, 26 Sep 2026 08:31:02 +0530 Sat, 26 Sep 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104221 Reassessment under Section 147 cannot be used to review conclusions reached in an original scrutiny assessment. Where the Assessing Officer had specifically examined depreciation claims, deductions, exempt-income expenditure and pre-production income, reopening based only on the same assessment record and a successor officer's different inference constitutes a change of opinion. In the absence of fresh tangible material, a false statement, or failure to make full and true disclosure of material facts, no jurisdictional reason to believe that income escaped assessment arises. The reassessment was therefore quashed and the revenue's appeal dismissed. Highlights Income Tax Sat, 26 Sep 2026 08:31:02 +0530 https://www.taxtmi.com/highlights?id=104221