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of The ITAT Nagpur considered the validity of reassessment proceedings u/s 147. The AO issued notice beyond four years alleging capital gain on 'Sale of Vehicles' escaped assessment. The tribunal held that the AO's reasons for reopening were a change of opinion as the issue was already examined during the original assessment. The AO did not prove failure to disclose material facts, as the assessee had provided sale agreements. Without new evidence, the AO lacked jurisdiction u/s 147 after four years. Since no failure to disclose facts was alleged, the reassessment was deemed invalid. Decision favored the assessee. - AO had initially made an addition u/s 68 regarding the sale of vehicles. The re-assessment proceedings attempted to reclassify this under u/s 50 or 41(2), which the Tribunal found to be a mere change of opinion and not permissible.
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