https://www.taxtmi.com/caselaws?id=472393 Reassessment cannot be initiated merely because the assessing authority later takes a different view of a capital-gain claim already examined in an original scrutiny assessment. Specific enquiries and disclosures concerning the sale of shares, capital-gain computation, and deduction claim established that the material relied on for reopening had been considered earlier. Sections 147 and 148 permit reassessment on legally sustainable grounds but do not confer a power to review a concluded assessment on the same material. Reopening founded solely on a change of opinion is therefore impermissible, rendering the order under section 148A(d) and the reassessment notice liable to be quashed. en-us Tue, 10 Mar 2026 00:00:00 +0530 Fri, 09 Oct 2026 21:34:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472393 Reassessment cannot be initiated merely because the assessing authority later takes a different view of a capital-gain claim already examined in an original scrutiny assessment. Specific enquiries and disclosures concerning the sale of shares, capital-gain computation, and deduction claim established that the material relied on for reopening had been considered earlier. Sections 147 and 148 permit reassessment on legally sustainable grounds but do not confer a power to review a concluded assessment on the same material. Reopening founded solely on a change of opinion is therefore impermissible, rendering the order under section 148A(d) and the reassessment notice liable to be quashed. Case-Laws Income Tax Tue, 10 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472393