https://www.taxtmi.com/caselaws?id=297481 The tribunal held that the reopening of assessment for AY 2005-06 was invalid as there was no failure on the part of the assessee to disclose material facts. The tribunal also ruled that the addition made on account of depreciation claimed on Goodwill was not sustainable as it was based on a change of opinion without any new evidence. Emphasizing the concept of 'change of opinion,' the tribunal dismissed the revenue's appeals for both AYs, upholding the decisions of the ld. CIT(A) and highlighting the necessity of tangible material to support reassessment beliefs. en-us Fri, 30 Oct 2015 00:00:00 +0530 Mon, 06 Sep 2021 22:10:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=297481 The tribunal held that the reopening of assessment for AY 2005-06 was invalid as there was no failure on the part of the assessee to disclose material facts. The tribunal also ruled that the addition made on account of depreciation claimed on Goodwill was not sustainable as it was based on a change of opinion without any new evidence. Emphasizing the concept of 'change of opinion,' the tribunal dismissed the revenue's appeals for both AYs, upholding the decisions of the ld. CIT(A) and highlighting the necessity of tangible material to support reassessment beliefs. Case-Laws Income Tax Fri, 30 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=297481