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The ITAT dismissed the revenue's appeal and upheld the CIT(A)'s order quashing the second reassessment. The Tribunal held that once assessment under s.143(3) was completed, the AO could not reopen the assessment absent non-disclosure of material facts; the second reopening sought to re-examine the same issue of beneficial ownership and treaty entitlement relying on identical material already considered in the first reassessment. No new material was placed on record nor was there a permissible change in circumstances justifying reassessment. Consequently, the second reassessment was treated as a mere change of opinion and invalid, and the AO's action was set aside.
The ITAT dismissed the revenue's appeal and upheld the CIT(A)'s order quashing the second reassessment. The Tribunal held that once assessment under s.143(3) was completed, the AO could not reopen the assessment absent non-disclosure of material facts; the second reopening sought to re-examine the same issue of beneficial ownership and treaty entitlement relying on identical material already considered in the first reassessment. No new material was placed on record nor was there a permissible change in circumstances justifying reassessment. Consequently, the second reassessment was treated as a mere change of opinion and invalid, and the AO's action was set aside.
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