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ITAT held that the reopening under sections 147/148 and the section 148A notice were invalid as issued on the same facts and documents already verified during original assessment, constituting a prohibited change of opinion; no new material was brought on record by the AO to sustain reopening. The Tribunal also deleted the addition under section 43CA, finding the stamp duty value-agreement value variance below the 5% margin applicable to AY 2016-17, and directed the AO to delete the impugned addition. Grounds raised by the Assessee in respect of the reopening and the section 43CA addition were allowed.
ITAT held that the reopening under sections 147/148 and the section 148A notice were invalid as issued on the same facts and documents already verified during original assessment, constituting a prohibited change of opinion; no new material was brought on record by the AO to sustain reopening. The Tribunal also deleted the addition under section 43CA, finding the stamp duty value-agreement value variance below the 5% margin applicable to AY 2016-17, and directed the AO to delete the impugned addition. Grounds raised by the Assessee in respect of the reopening and the section 43CA addition were allowed.
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