#Section 147
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Reassessment on the basis of information received under treaty is valid
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Reopening on the basis of information of accommodation entries justified
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No change of opinion if AO not examined or applied his mind on a particular issue-HC
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Reopening on the ground on which AO already held detailed discussion during original Assessment is not valid
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Reopening based on Second thought on same material not valid – SC
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Reversal of law by Supreme Court does not justify reopening
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Reopening on the basis of approval from CIT instead of JCIT/Addl. CIT is not valid
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Reopeing of Assessment to verify compliance with provisions amended in future is invalid
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Re-assessment held to be void if AO has not analysed in detail the reasons of reopening
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Assessment cannot be reopened u/s 147 in absence of tangible material
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Re-opening of assessment for change of opinion not valid – SC
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Section 147 cannot be invoked for amendment with retrospective effect
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Fishing inquiries unconnected with reasons recorded in reassessment proceedings not allowed
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