https://www.taxtmi.com/caselaws?id=61432 Reassessment under section 147 cannot be used to introduce a fresh disallowance on an issue already considered in the original section 143(3) assessment without notice to the assessee on that specific point. Where the disputed interest payment had been examined earlier and no disallowance was made, a later disallowance under section 40(b) in reassessment amounted to a change of opinion on the same material and breached the requirement of fair notice. The disallowance was therefore held unsustainable and directed to be deleted. en-us Fri, 12 Jan 1990 00:00:00 +0530 Wed, 12 Jan 2011 16:03:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61432 Reassessment under section 147 cannot be used to introduce a fresh disallowance on an issue already considered in the original section 143(3) assessment without notice to the assessee on that specific point. Where the disputed interest payment had been examined earlier and no disallowance was made, a later disallowance under section 40(b) in reassessment amounted to a change of opinion on the same material and breached the requirement of fair notice. The disallowance was therefore held unsustainable and directed to be deleted. Case-Laws Income Tax Fri, 12 Jan 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61432