Commissioner of Income Tax v. Kelvinator of India Ltd - Scope of reassessment under Section 147/148

The Supreme Court (Constitutional Bench) held that after the 1989 amendment to Section 147, the Assessing Officer cannot reopen a completed assessment merely on a change of opinion. Reassessment under Section 147 requires "reason to believe" that income has escaped assessment - this implies tangible material or new information, not merely a different view on the same facts. Established the principle that "change of opinion" does not constitute valid ground for reopening. Remains foundational for challenging unlawful reassessment notices under Section 148.

curl https://api.thynktax.com/v1/tax-law/case-laws?q=Commissioner%20of%20Income%20Tax%20v.%20Kelvinator%20of%20India%20Ltd%20-%20Scope%20of%20reassessment%20under%20Section%20147%2F148