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ITAT allowed the assessee's appeal and quashed reassessment proceedings initiated u/s 147/148 beyond four years. It held that during the original scrutiny, the AO had examined in detail the assessee's claim for deduction u/s 80IA(4)(iii) based on audited accounts and supporting documents. In the recorded reasons, the AO relied solely on the very same material without identifying any failure by the assessee to fully and truly disclose material facts or specifying any new tangible material leading to escapement of income. Treating the exercise as a mere change of opinion and an impermissible review, ITAT held the reopening invalid and restored the original assessment.
ITAT allowed the assessee's appeal and quashed reassessment proceedings initiated u/s 147/148 beyond four years. It held that during the original scrutiny, the AO had examined in detail the assessee's claim for deduction u/s 80IA(4)(iii) based on audited accounts and supporting documents. In the recorded reasons, the AO relied solely on the very same material without identifying any failure by the assessee to fully and truly disclose material facts or specifying any new tangible material leading to escapement of income. Treating the exercise as a mere change of opinion and an impermissible review, ITAT held the reopening invalid and restored the original assessment.
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