https://www.taxtmi.com/caselaws?id=312196 The ITAT Mumbai upheld the CIT(A)'s decision to quash a reassessment order passed by the AO under sections 143(3) and 147. The AO had reopened the assessment after 4 years on the same facts previously considered during the original assessment under section 143(3), merely changing the treatment of prior period expenses and income without any fresh material indicating income escapement. The ITAT held that reopening based solely on change of opinion without new material or non-disclosure by the assessee was invalid. The revenue's appeal was dismissed. en-us Fri, 09 Mar 2018 00:00:00 +0530 Tue, 06 Feb 2024 23:10:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312196 The ITAT Mumbai upheld the CIT(A)'s decision to quash a reassessment order passed by the AO under sections 143(3) and 147. The AO had reopened the assessment after 4 years on the same facts previously considered during the original assessment under section 143(3), merely changing the treatment of prior period expenses and income without any fresh material indicating income escapement. The ITAT held that reopening based solely on change of opinion without new material or non-disclosure by the assessee was invalid. The revenue's appeal was dismissed. Case-Laws Income Tax Fri, 09 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312196