https://www.taxtmi.com/caselaws?id=472507 Reassessment under Section 147 requires a reason to believe that income escaped assessment, founded on fresh tangible material; it cannot be used to review matters examined during the original scrutiny assessment. Reliance on financial documents and other material already available in the original proceedings, without subsequently identified tangible material, amounts to an impermissible change of opinion. An audit objection alone cannot support reopening where it does not disclose fresh material indicating escaped income. Reassessment initiated on that basis is jurisdictionally invalid and liable to be quashed. en-us Tue, 22 Apr 2025 00:00:00 +0530 Wed, 14 Oct 2026 13:28:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472507 Reassessment under Section 147 requires a reason to believe that income escaped assessment, founded on fresh tangible material; it cannot be used to review matters examined during the original scrutiny assessment. Reliance on financial documents and other material already available in the original proceedings, without subsequently identified tangible material, amounts to an impermissible change of opinion. An audit objection alone cannot support reopening where it does not disclose fresh material indicating escaped income. Reassessment initiated on that basis is jurisdictionally invalid and liable to be quashed. Case-Laws Income Tax Tue, 22 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472507