Tag Archives: Mahendra Gumanmalji Lodha

Reassessment based on previously examined bank records without new tangible material constitutes impermissible change of opinion.

By | August 21, 2026

Reassessment based on previously examined bank records without new tangible material constitutes impermissible change of opinion. Issue Whether an assessment completed under Section 143(3) can be reopened under Section 147 to examine bank credits and gross receipts that were already scrutinized, in the absence of any new tangible material. Facts Assessee’s return for AY 2012-13… Read More »

Reopening Assessment Without New Tangible Material Amounts To Invalid Change Of Opinion

By | August 20, 2026

Reopening Assessment Without New Tangible Material Amounts To Invalid Change Of Opinion Reopening Assessment Without New Tangible Material Amounts To Invalid Change Of Opinion Issue Whether reopening an assessment under Section 147 based on an Investigation Wing report is legally sustainable when no new tangible material was discovered and the original assessment under Section 143(3)… Read More »