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“tangible material”

ReassessmentSection 147Section 1472,812 judgments

The decision most relied on for tangible material is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on tangible material

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

PCIT v. RMG Polyvinyl (I) Ltd.
396 ITR 5 · 2017 · High Court
272
citing judgments

Reassessment based solely on information from the Investigation Wing, without the Assessing Officer conducting further inquiry or demonstrating an independent application of mind, is unjustified and invalid.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Judgments citing tangible material

DCIT-2(1)(1), Mumbai vs. Bank of Baroda, Mumbai

In the result, both the appeals filed by the Revenue and both the cross objections

ITA 4869/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri C. Naresh, ARFor Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 115JSection 143(3)Section 147Section 14ASection 244ASection 250Section 36(1)(viia)

holding reopening u/s. 147 of the Act not valid and the quashing impugned assessment order failing to consider that revenue audit objections are tangible material. 3. The appellant craves the leaves to add, amend, alter and/or delete any of the grounds of appeals of appeal as above.” Grounds raised ... allowed the appeal filed by the assessee challenging the validity of the reopening of the assessment on the ground that there was no new tangible material available with the Ld. AO for reopening the assessment and the same was only on the basis of the return of income, tax audit

Rohit Manchand, Delhi vs. ITO Ward 5(3)(2), Gautam Budh Nagar

In the result, appeal filed by the assessee is allowed

ITA 5124/DEL/2025[2012-13]Status: DisposedITAT Delhi12 Feb 2026AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

For Appellant: Sh. Raj Kumar, CA &For Respondent: Ms. Ankush Kalra, Sr.DR
Section 139Section 142(1)Section 144Section 147Section 148Section 151Section 50cSection 54

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘E’: NEW DELHI. BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI

Gulmohar Towers Private Limited, Kolkata vs. Income Tax Officer, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 976/KOL/2025[2011-12]Status: DisposedITAT Kolkata10 Feb 2026AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S. Jhajharia, ARFor Respondent: Shri P.N. Barnwal, DR
Section 143(1)Section 147Section 148Section 148(2)

failure on the part of the assessee to disclose fully and truly all material facts qua the sale of investments. Therefore, there was no tangible material on record which suggests the escapement of income. We observe that there was non-application of independent mind by the Id. AO, lack ... there was no Page ITA No. 976/KOL/2025 Gulmohar Towers Private Limited; A.Y. 2011-12 independent application of mind by the AO to the tangible material which forms the basis of the reasons to believe that income has escaped assessment. The Hon'ble High Court has held that the conclusions

Assistant Commissioner of Income Tax, Central Circle-2(1), Chennai vs. M/S Radaan Media Works India Limited, Teynampet

In the result, appeal of the revenue is dismissed

ITA 2136/CHNY/2025[2015-16]Status: DisposedITAT Chennai10 Feb 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.2136/Chny/2025 "नधा"रण वष"/Assessment Year: 2015-16 V. Acit, M/S Radaan Media Works Central Circle 2(1), India Limited, Chennai-600034 14 Jayammal Road, Chennai -600018 [Pan: Aabcr3815L] (अपीलाथ"/Assessee) (""यथ"/Respondent)

Section 131Section 132Section 132(44)Section 133ASection 142(1)Section 153CSection 69C

Common Cause v. Union of India, it was contended that statements recorded during survey proceedings have no evidentiary value unless supported by tangible material. The loose sheet relied upon by the AO, by itself, does not establish undisclosed income, especially when the transactions are already reflected in the books

DCIT, Central Circle 7(1), Mumbai vs. Dr D Y Patil Educational Academy, Mumbai

In the result, the appeal filed by the revenue stands

ITA 3922/MUM/2025[2015]Status: DisposedITAT Mumbai10 Feb 2026

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 132Section 147Section 153CSection 250Section 68

that the re-opening of assessment to be successful has to be tested on the touchstone of 'reason to believe' on the basis of tangible material that income has escaped assessment. There should be a live link between the tangible material and the formation of belief on the basis

Abhimanyu Gupta, Patiala vs. Dy. Commissioner of Income Tax, Circle-Patiala, Patiala

In the result, the appeal of the assessee is allowed

ITA 979/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh09 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 115BSection 144BSection 147Section 148Section 153CSection 69

assessment is illegal, arbitrary and unjustified. 3. That the learned Commissioner of Income Tax (Appeals) has failed to appreciate that there was no tangible material on record that income of the appellant had escaped assessment which is based only on borrowed information that also extracted from some computers of third ... argued that the addition is purely based on "borrowed information" extracted from the computers of third parties. The AR emphasized that no tangible material was found in the possession of the assessee and that the revenue failed to discharge its burden by not allowing cross-examination of the persons whose

DCIT, CC-3, Ludhiana, Kitchlu Nagar vs. Mani Ram Balwant Rai HUF, Civil Lines

The appeal of the Revenue is dismissed

ITA 1043/CHANDI/2024[2022-23]Status: DisposedITAT Chandigarh09 Feb 2026AY 2022-23

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Smt. Geetinder Mann, CIT DR
Section 127Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 144BSection 145(3)Section 28Section 69C

Tribunal held that:  DML reports and digital data cannot be the sole basis for quantifying unaccounted sales.  Estimation must be based on tangible material.  Arbitrary application of excessive GP rates is impermissible.  GP should be aligned with industry norms and actual GST impact. 6.2 The Hon’ble Tribunal ultimately determined ... reproduced herein for ready reference: “We do find force in the argument of the assessee that the estimation should be based upon some tangible material… application of enhanced GP rate is arbitrary and excessive… to meet the ends of justice, we are inclined to levy a GP rate

Amiben Rajeshkumar Punatar, Rajkot vs. ITO, Ward-1(2)(1), Rajkot

In the result, the appeal filed by the assessee is allowed

ITA 24/RJT/2026[2015-16]Status: DisposedITAT Rajkot06 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.24/Rjt/2026 िनधा"रण वष"/Assessment Year : 2015-16 Amiben Rajeshkumar Punatar, बनाम/ Ito, Ashish, 41-New Jagnath Plot, Vs Ward – 1(2)(1), Rajkot – 360001(Gujarat) Rajkot "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahrpp4181F (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 10(38)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 250

Amiben Rajeshkumar Punatar 7. Shri Mehul Ranpura, learned Counsel for the assessee, argued that there is no whisper in the reasons recorded, of any tangible material which came to the possession of the assessing officer subsequent to the completion of regular assessment under section ... said long-term capital gain and framed the assessment order under section 143(3) of the Act. Hence, there is no any new tangible material with the assessing officer to reopen the concluded assessment after four years. Besides, there is no failure on the part of the assessee to disclose

Sudha Luhadia, Indore, M.P vs. The ITO - 4(5), Indore, M.P

In the result, the impugned order is upheld

ITA 546/IND/2025[2017-18]Status: DisposedITAT Indore06 Feb 2026AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M Joshisudha Luhadia, Indore The Ito-4(5), बनाम/ C/O S.V. Agrawal & Indore Vs. Associates, 25, Joy Builders Colony, Near Rafael Tower, Old Palasia, Indore (Mp) (Pan: Abapl5445M) (Appellant) (Respondent) Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 09.12.2025 Date Of Pronouncement 06.02.2026 आदेश/ O R D E R

Section 115Section 115BSection 143(3)Section 234ASection 250Section 253Section 271ASection 69Section 69A

been found to be of third parties. Source of cash deposit of Rs. 5 Lakh or 8 Lakh have not been proved by any tangible material record. Except bald statements / explanation no credible evidence has been placed on record to justify sources despite full and complete opportunities to the assessee ... receipts and bank withdrawals. Hence undisclosed income is proved. 4.12 The assessee has not able to establish sudden spike in cash sales by any tangible material worth credence. How much material came, from whom it has come, how much job work was done of embroidery, stitching and ironing

Kuldip Kumar Goel, Delhi vs. ACIT(1)(1), Delhi

In the result, the appeal of the assessee is partly allowed in above

ITA 3285/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Raj Kumar Chauhanand

Section 143(3)Section 144Section 147Section 148Section 149(1)Section 250

initiation of reassessment proceedings, satisfaction drawn by Ld. JAO was inadequate as condition precedent was not satisfied. Appellant averred that the link between tangible material and formation of belief was missing. If there is relevant material based on which a reasonable person can form a requisite belief that income chargeable ... sine qua non to exercise the jurisdiction under Section 147 of the Act. The expression ‘reason to believe’ requires following four elements viz. a) tangible material or materials to establish that income has escaped assessment b) nexus between such material and the belief of escapement of income from assessment

DCIT, Vikash Bhawan Delhi vs. Rajan Kumar, Laxmi Nagar, Delhi

In the result, the appeal of the Revenue appeal is dismissed and the cross objection filed by the assessee is allowed in the aforesaid manner

ITA 130/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Sudhir Kumar & Smt. Renu Jauhridcit Vs Rajan Kumar Room No. 218-D Block, 31,Vijay Block Laxmi Vikash Bhawan, Nagar Delhi-110092 Delhi- 110 002 Pan: Caapk8381E

Section 132Section 142(1)Section 143(1)Section 147Section 148Section 69A

Delhi In this case the Hon’ble High Court held that there is no independent application of mind by the AO to the tangible material which forms the basis of the reasons to believe that income has escaped assessment. The conclusive of the AO are at best a reproduction ... conclusion in the investigation report. Indeed, it is a ‘borrowed satisfaction’. The reasons fail to demonstrate the link between the tangible material and the formation of the reason to believe that income has escaped assessment. (ii) CIT v. Insecticide (India) Ltd. {201} 38 taxmann. Com 403 (Delhi) (iii) PCIT

ACIT, New Delhi vs. Nouvelle Securities Pvt Ltd, Delhi

In the result, the appeal of the Revenue in ITA No

ITA 4852/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Manoj Tiwari, Sr. DR
Section 132Section 132(4)Section 153ASection 37Section 68Section 69C

assessment order passed by the AO not sustainable. Thus the additions made by the AO on the basis of such statement without any tangible material is not sustainable in law and liable to be deleted. 39. In view of the above discussion and further looking to the fact that when ... genuineness of transaction and creditworthiness of the loan creditors. On a broader reckoning, the apprehension raised by the Revenue authorities militates against the tangible material and is thus extraneous. Accordingly, we find no infirmity in the order of ld. CIT(A) in deleting the additions made u/s 68 towards

Lakhvir Singh, Bathinda vs. ITO, Ward 1(1), Btd, Bathinda

The appeal stand partly allowed for statistical purposes

ITA 63/ASR/2025[2014-15]Status: DisposedITAT Amritsar05 Feb 2026AY 2014-15

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm

For Appellant: Sh. Vipul Arora (CA) – Ld. ARFor Respondent: Sh. Charan Dass (Addl. CIT) - Ld. Sr DR
Section 147

considered opinion, it was not incumbent upon Ld. AO to quantify the exact escapement of income. The only requirement was possession of tangible material suggesting escapement of income. This condition, in the present case, has duly been fulfilled and therefore, no fault could be found in reopening. The corresponding legal

Ambuja Cements Limited, Mumbai vs. PCIT, Mumbai-3, Mumbai

ITA 3474/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Sourabh Soparkar, AR (virtually appear)For Respondent: Shri Rajesh Kumar Yadav, (CIT-DR)
Section 143(3)Section 14ASection 263

conduct a fresh enquiry, without recording a finding of error in original assessment. It is argued that in the absence of tangible material demonstrating error, assumption of jurisdiction u/s 263 is devoid of foundation and Page | 7 ITA No. 3474/Mum/2025 A.Y. 2019-20 Ambuja Cements Limited, Mumbai therefore

Ba Continuum India Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

ITA 368/HYD/2024[2005-06]Status: DisposedITAT Hyderabad04 Feb 2026AY 2005-06

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 10ASection 142(1)Section 143(2)Section 147Section 40

Satisfaction of the JCIT was not obtained before initiating the reassessment proceedings under section 147 of the Act. b) No evidence of any new tangible material has been referred to by the Ld. AO in the reasons for re-opening the assessment and hence, it is a mere change

Shamim Ahmad, Muzaffarnagar vs. Income Tax Officer, Ward 3 (2)(4) Mzr, Muzaffarnagar

In the result, the appeal of the assessee in ITA No

ITA 4241/DEL/2024[2012-13]Status: DisposedITAT Delhi04 Feb 2026AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(3)Section 147Section 148

that there is stark absence of live nexus Page 2 of 4 ITA No. 4241/DEL/2024 [A.Y. 2012-13] Shamim Ahmad Vs ITO between the tangible material available on record and reasons recorded to take a view that the assessee is showing low net profit. 7. Furthermore, we find that

Neeraj Kumar, Agra vs. Income Tax Officer Ward 2(1)(3), Agra

In the result, the appeal of the Assessee is allowed for statistical purposes

ITA 538/AGR/2025[2011-12]Status: DisposedITAT Agra03 Feb 2026AY 2011-12

Bench: Shri M. Balaganeshneeraj Kumar, Vs. Income Tax Officer, 18/24, Ghadi Hussaini Ward-2(1)(3), Prakash Nagar, Agra Agra (Appellant) (Respondent) Pan: Ajwpn8393C Assessee By : Shri Jitendra Garg, Adv Shri Pradumn Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 03/02/2026

For Appellant: Shri Jitendra Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 139Section 144Section 147Section 148Section 154Section 250Section 271(1)(b)Section 44ASection 69A

denied proper opportunity of being heard. 5. Because the reopening under section 147 is mechanical, without application of mind, based on no new tangible material, and in violation of the procedure laid down in GKN Driveshafts for supply of reasons and disposal of objections. 6. Because cash deposits

Devkrupa International, Bhavnagar vs. The Assistant Commissioner of Income-Tax Circle -1 Bhavnagar, Bhavnagar

In the result, the appeal of the assessee is allowed

ITA 820/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyaldevkrupa International, The Assistant Commissioner Vs. Shop No.1 Navkar Tower, Of Income-Tax Circle-1, Kalubha Road, Bhavnagar Bhavnagar – 364001 [Pan: Aaefd0184G] (Appellant) .. (Respondent) Appellant By: Shri Tushar Hemani, Sr. Advocate Respondent By: Shri Abhijit, Sr. Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Abhijit, Sr. DR
Section 143(1)Section 147Section 148Section 250Section 68

Revenue Authorities. The Ld. AR argued that the reasons recorded do not disclose the nature, date, or source of alleged transactions, nor any tangible material suggesting escapement of income. 7. The Ld. DR, on the other hand, relied upon the order of the authorities below. 8. We have carefully considered ... hold that the reopening of assessment u/s 147 is based on borrowed satisfaction, without independent application of mind, and in absence of any tangible material. Consequently, the reassessment proceedings are held to be invalid in law and are hereby quashed. 8.4 Since the facts reveal that the amounts credited

Kishorbhai Dattani, Jam Khambhalia vs. Income Tax Officer, Ward -1, Dwarka

In the result, the appeal of the assessee is allowed

ITA 555/RJT/2025[2017-18]Status: DisposedITAT Rajkot02 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 555/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Kishorbhai Dattani Vs. Income Tax Office, Hospital C/O. Sarda & Sarda (Ca), Sakar 1St Road, Near Rajdhani Hotel, Floor, Dr. Radha-Krishnan Road, Dwarka, Gujarat 361335 Opp. Rajkumar College, Rajkot, Rajkot Gujarat 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakpd7272M (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 03 / 11 /2025 Date Of Pronouncement : 02/ 02 /2026

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR
Section 115BSection 144BSection 147Section 148Section 250Section 69A

following observation: “The appellant has objected to the validity of reopening, inter alia, on the ground that the reasons recorded did not constitute a tangible material leading to the formation of belief that income had escaped assessment. However, I find that the information relied upon by the Assessing Officer ... specific and pointed to a transaction (advance of Rs. 10,00,000/-), and thus constituted tangible material for initiating proceedings u/s 147. Further, the reasons were duly recorded and the notice u/s 148 was issued after following the due process of law. The appellant was given opportunity to raise objections

Pawan Garg, Panchkula vs. ITO Ward 5((5) Chandigarh, Chandigarh

In the result, appeal of the assessee is allowed

ITA 1218/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh02 Feb 2026AY 2014-15

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1218/Chd/2024 "नधा"रण वष" / Assessment Year: 2014-15 Shri Pawan Garg, The Ito, House No. 766, Sector 16, Vs Ward 5(5), Panchkula. Chandigarh. "थायी लेखा सं./Pan No: Abmpg4243N अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 27.01.2026 Date Of Pronouncement : 02.02.2026

For Appellant: Shri Ajay Jain, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 139Section 142(1)Section 147Section 148Section 234ASection 271Section 271(1)(c)Section 271FSection 68

exhibiting the alleged modus- operandi, but how it is connected with the assessee, nothing has been discussed in the reasons. Therefore, there was no tangible material available with the AO for forming a belief that income has escaped assessment. He submitted that re- opening is bad in the eyes ... background material available with the AO for formation of belief that income has escaped assessment. In other words, there is no live nexus between tangible material possessed by the AO vis- a-vis formation of belief that income has escaped assessment. Accordingly, the re-opening of assessment