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Kelvinator of India

Supreme Court of India·2010·ITR
Facts

Notice for reassessment issued under old Section 147/148.

Issue

When can the AO reopen an assessment - "reason to believe" requirement?

Held

Mere change of opinion is not sufficient; the AO must have tangible material to form belief that income has escaped.

Ratio

Reassessment is not a tool to revisit completed assessments; requires fresh material.

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