Reassessment cannot be initiated on a change of opinion without fresh tangible material following appellate finality.

The Petitioner, a Hindu Undivided Family (HUF), filed its return for A.Y. 2022-23 declaring an income of Rs. 8,24,770/-

The Centralized Processing Center (CPC) restricted the claimed TDS credit, leading the Petitioner to file a rectification application and subsequently an appeal

On 04.12.2025, the Commissioner of Income Tax (Appeals) ["CIT(A)"] allowed the appeal, accepting the Petitioner’s reconciliation of interest income and directing full TDS credit

Despite this final appellate order, the Respondents issued a sanction note on 20.03.2026 and a notice under Section 148 on 23.03.2026 to reopen the assessment based on the same interest income discrepancy flagged by the "Insight Portal"

The Petitioner challenged these proceedings under Article 226 of the Constitution.

1. Whether the Assessing Officer had jurisdiction to issue a notice under Section 148 based on information that was already adjudicated upon by a superior appellate authority

2. Whether the reopening of assessment based on identical facts and materials constitutes an impermissible "change of opinion"

The court primarily applied Section 147 and Section 148 of the Income Tax Act, 1961, regarding the power to reassess escaped income

reassessment cannot be based on a mere "change of opinion" and requires fresh "tangible material" (CIT v. Kelvinator of India Ltd.)

An Assessing Officer cannot override a binding order of an appellate authority (CIT(A)) on the same set of facts based on the doctrine of judicial discipline.

The Court observed that the issues raised in the sanction note—specifically the alleged mismatch between interest income and Form 26AS—were the exact subjects of the CIT(A)’s order dated 04.12.2025

The CIT(A) had already verified that the Petitioner had disclosed the total interest income under different heads (Business Income and Other Sources)

The Court found that the Revenue did not present any "fresh, specific, or tangible material" discovered after the appellate order

Consequently, the Assessing Officer’s attempt to reopen the assessment was characterized as a "second innings" to re-appreciate existing evidence, which is prohibited under the guise of reassessment

the Revenue did not challenge the CIT(A) order, it had attained finality, and the Section 148 notice amounted to a collateral attack on that final adjudication

The Court allowed the writ petition and quashed the Section 148 notice dated 23.03.2026, the sanction note dated 20.03.2026, and all consequential proceedings

The Petitioner was granted relief on the grounds that the Assessing Officer exceeded his authority by revisiting a matter already concluded by a quasi-judicial appellate authority