35 ITR 1 (SC), CIT v. A. Raman and Co.

82 ITR 831Supreme Court of India1971#2659 most cited

What is 35 ITR 1 (SC), CIT v. A. Raman and Co. authority for?

Reassessment under Section 147 is not permissible solely on a mere change of opinion or a reconsideration of the same material. The Assessing Officer loses jurisdiction to proceed with reassessment if the initial grounds for believing income has escaped assessment are subsequently found to be incorrect or non-existent.

44

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. A. Raman and Co. · 82 ITR 831 · Section 147 · Section 148 · reassessment · mere change of opinion · jurisdiction to reassess · grounds incorrect · escaped assessment · Bankipur Club Ltd. · Kelvinator · no new material

Issues it is cited on

Judgments citing 35 ITR 1 (SC), CIT v. A. Raman and Co.