https://www.taxtmi.com/caselaws?id=415541 The Tribunal upheld the decision to quash the reassessment order, finding the reopening invalid due to being based on a mere change of opinion without new material. The Assessing Officer lacked fresh material to justify the reopening, leading to a change of opinion, which is impermissible. The reopening was solely on re-examining existing facts, not new information. Additionally, reopening based on an audit objection was deemed invalid. The CIT(A) not adjudicating merits was considered unnecessary post invalidation of the reassessment order. The revenue's appeal was dismissed. en-us Wed, 01 Dec 2021 00:00:00 +0530 Tue, 07 Dec 2021 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415541 The Tribunal upheld the decision to quash the reassessment order, finding the reopening invalid due to being based on a mere change of opinion without new material. The Assessing Officer lacked fresh material to justify the reopening, leading to a change of opinion, which is impermissible. The reopening was solely on re-examining existing facts, not new information. Additionally, reopening based on an audit objection was deemed invalid. The CIT(A) not adjudicating merits was considered unnecessary post invalidation of the reassessment order. The revenue's appeal was dismissed. Case-Laws Income Tax Wed, 01 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415541