S. 147: Reassessment-Within four years-Reason to believe-Intimation under S. 143(1)-Reopening notice based on a system-generated alert from the Non-Filer Management System (NMS) without independent application of mind is invalid. [S. 68,139, 143(1), 148, Art. 226]

S. 147: Reassessment-Change of opinion-Enquiry during original assessment-Where Assessing Officer has raised a specific query during original assessment proceedings to which the assessee has replied, the issue is deemed to have been examined-Reopening assessment on the very same issue, even if not discussed in the assessment order, constitutes an impermissible change of opinion. [S. 37(1), 142(1), 148, Art. 226]

S. 147 : Reassessment-Within four years-Change of opinion-Prior period expenditure-Order of tribunal quashing the reassessment is affirmed. [S. 37(1), 260A]

S. 147 : Reassessment-Reason to believe-Jurisdiction-Unexplained money-Notice based on fundamentally wrong facts pertaining to a different entity-Constitutes non-application of mind-Reopening invalid. [S 69A, 148, 151, Art. 226]

S. 147 : Reassessment-Charitable or religious trust –-Non-application of mind-Receipts from charitable activities mistaken for commercial income-Reopening notice based on mechanical reasoning and factual errors quashed. [S. 11, 143(1) 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years / Within four years-Reasons to believe-Reopening based on borrowed information from DRI or Justice M.B. Shah Commission Report without independent application of mind by AO is not permissible-Failure to disclose material facts cannot be alleged based on a subsequent Supreme Court ruling. [S. 148, Art. 226]

S. 147 : Reassessment-After expiry of four years-Scrutiny assessment-Where original assessment was completed after a detailed scrutiny of the assessee’s share transactions, a subsequent reopening of assessment on the same issue based on information regarding ‘client code modification’ is invalid, as there was no failure on the part of the assessee to disclose material facts fully and truly. [S. 68,143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-No failure to disclose material facts-Audit objection not new tangible material-Reassessment notice and order disposing the objection is quashed. [S 36(1)(vii), 36(2), 45, 143(3) 148, Art. 226]

S. 147: Reassessment-After expiry of four years-Change of opinion-Interest income capitalized to Work-in-Progress and non-addition of provision for income-tax-Issues were subject-matter of query during original assessment-Reopening held to be based on mere change of opinion and hence invalid. [S. 4, 56, 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Excess investment in shares-Where reasons for reopening were based entirely on financial statements already on record during the original assessment, it amounted to a mere change of opinion and was not sustainable as there was no failure on the part of the assessee to disclose material facts fully and truly. [S. 14A, 69, 148, Art. 226]