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Change of Opinion Based on Existing Records Held Invalid; Section 148 Notice Set Aside

SEO Expert February 18, 2026

The Court ruled that reopening based solely on an audit objection amounts to change of opinion if the issue was previously examined. Without fresh tangible material, reassessment proceedings are unsustainable.

The post Change of Opinion Based on Existing Records Held Invalid; Section 148 Notice Set Aside appeared first on TaxGuru.

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Previous: Sec 263 Revision Quashed – Reopening Without Tangible Material Invalid & PCIT Failed to Conduct Independent Enquiry – ITAT Amritsar
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