Reopening Income Tax Assessment Needs New Info, Prior Approval; Mere Opinion Change Isn't Enough, Says Recent Ruling.

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....Provisions and requirements for reopening an assessment u/s 147 of the Income Tax Act, 1961, as amended. It emphasizes that mere 'change of opinion' without any new material on record is not sufficient for reopening an assessment. The key points are: (1) The Assessing Officer (AO) must have information suggesting that income chargeable to tax has escaped assessment and obtain prior approval from the specified authority to issue a notice u/s 148, unless an order u/s 148A(d) has been passed with prior approval. (2) The notice u/s 148 must precede the inquiry u/s 148A and comply with the time limit u/s 149. (3) Sanction from the specified authority is required before issuing notices u/ss 148 and 148A. (4) Fresh and tangible materials must be a.........