https://www.taxtmi.com/caselaws?id=151254 The Income Tax Appellate Tribunal (ITAT) dismissed the Revenue's appeal, ruling that the reopening of the assessment under section 147/148 was invalid as it constituted a mere change of opinion without new material facts. The ITAT upheld the Commissioner of Income-tax (Appeals) decision, emphasizing that the disallowance of depreciation and expenses lacked justification as it was based on the same facts already considered during the original assessment. Consequently, the appeal on the disallowance of depreciation and expenses was deemed unnecessary. en-us Fri, 05 Feb 2010 00:00:00 +0530 Mon, 03 Jun 2013 11:00:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=151254 The Income Tax Appellate Tribunal (ITAT) dismissed the Revenue's appeal, ruling that the reopening of the assessment under section 147/148 was invalid as it constituted a mere change of opinion without new material facts. The ITAT upheld the Commissioner of Income-tax (Appeals) decision, emphasizing that the disallowance of depreciation and expenses lacked justification as it was based on the same facts already considered during the original assessment. Consequently, the appeal on the disallowance of depreciation and expenses was deemed unnecessary. Case-Laws Income Tax Fri, 05 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=151254