https://www.taxtmi.com/caselaws?id=799784 Reassessment under section 147 cannot serve as a review of claims already examined in the original scrutiny assessment. A valid reason to believe income escaped assessment requires a live nexus with tangible material; a changed inference from existing assessment records is insufficient. Where queries on depreciation, expenditure disallowance and pre-production income were raised and answered, and recorded reasons identify no fresh material or failure of full and true disclosure, reopening lacks jurisdiction. The resulting reassessment order is invalid as founded on a mere change of opinion. en-us Thu, 24 Sep 2026 00:00:00 +0530 Sat, 26 Sep 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799784 Reassessment under section 147 cannot serve as a review of claims already examined in the original scrutiny assessment. A valid reason to believe income escaped assessment requires a live nexus with tangible material; a changed inference from existing assessment records is insufficient. Where queries on depreciation, expenditure disallowance and pre-production income were raised and answered, and recorded reasons identify no fresh material or failure of full and true disclosure, reopening lacks jurisdiction. The resulting reassessment order is invalid as founded on a mere change of opinion. Case-Laws Income Tax Thu, 24 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799784