https://www.taxtmi.com/caselaws?id=253335 The Tribunal dismissed the Department's appeal, upholding the CIT(A)'s decision that the reopening of assessment beyond four years was invalid. The Assessing Officer's actions were deemed impermissible as they constituted a change of opinion without new material, particularly regarding the treatment of interest income and claimed business expenditure. The Tribunal emphasized the importance of consistent accounting practices and the need for valid reasons, not mere changes of opinion, to justify reopening assessments under Section 147. en-us Wed, 10 Sep 2014 00:00:00 +0530 Fri, 21 Nov 2014 12:13:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253335 The Tribunal dismissed the Department's appeal, upholding the CIT(A)'s decision that the reopening of assessment beyond four years was invalid. The Assessing Officer's actions were deemed impermissible as they constituted a change of opinion without new material, particularly regarding the treatment of interest income and claimed business expenditure. The Tribunal emphasized the importance of consistent accounting practices and the need for valid reasons, not mere changes of opinion, to justify reopening assessments under Section 147. Case-Laws Income Tax Wed, 10 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253335