https://www.taxtmi.com/caselaws?id=406622 The Appellate Tribunal dismissed the Revenue's appeal, affirming the CIT(A)'s decision that the re-opening of the assessment under Section 147 was invalid. The Tribunal found that the re-assessment was based on a change of opinion by the Assessing Officer, which is not a valid ground. Additionally, the re-opening exceeded the permissible period of four years and did not involve any failure to disclose material facts by the assessee. Therefore, the Tribunal held that the re-opening was unjustified and not in compliance with the Income Tax Act. en-us Fri, 16 Apr 2021 00:00:00 +0530 Mon, 19 Apr 2021 20:33:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406622 The Appellate Tribunal dismissed the Revenue's appeal, affirming the CIT(A)'s decision that the re-opening of the assessment under Section 147 was invalid. The Tribunal found that the re-assessment was based on a change of opinion by the Assessing Officer, which is not a valid ground. Additionally, the re-opening exceeded the permissible period of four years and did not involve any failure to disclose material facts by the assessee. Therefore, the Tribunal held that the re-opening was unjustified and not in compliance with the Income Tax Act. Case-Laws Income Tax Fri, 16 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406622