ITO v. TechSpan India (P) Ltd.
92 Taxmann.com 361Supreme Court of India2018#485 most cited
What is ITO v. TechSpan India (P) Ltd. authority for?
Reassessment under Section 147/148 is invalid if it constitutes a mere change of opinion by the Assessing Officer without any fresh tangible material, especially after the assessee made a full and truthful disclosure during the original scrutiny assessment under Section 143(3).
194
judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2017 to 2026.
Also referred to as
ITO v. TechSpan India (P) Ltd. · Section 147 · Section 148 · Section 143(3) · mere change of opinion · reopening of assessment · reassessment validity · tangible material · full disclosure · scrutiny assessment · reason to believe