5. Amar Jewellers Ltd. v. ACIT
139 Taxmann.com 198High Court2022#9379 most cited
What is 5. Amar Jewellers Ltd. v. ACIT authority for?
An Assessing Officer cannot reopen an assessment based solely on a change of opinion, absent tangible material indicating escapement of income. Reopening requires a reason to believe income has escaped assessment, not merely a new perspective on existing facts.
11
judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2023 to 2025.
Also referred to as
Amar Jewellers Ltd. v. ACIT · section 147 · section 148 · reassessment · change of opinion · reason to believe · escapement of income · inaccurate particulars · borrowed satisfaction