https://www.taxtmi.com/caselaws?id=752653 The HC held that Section 147 reassessment proceedings were invalid as they were based on change of opinion rather than reason to believe. The assessee had fully disclosed interest transactions in the original assessment. The AO had consciously examined and treated interest paid/received as capital items instead of revenue items after applying his mind. The revenue's subsequent attempt to tax interest receipt as revenue was merely a change of opinion, not grounds for reopening under Section 147. The tribunal correctly set aside the reassessment proceedings in favor of the assessee. en-us Mon, 06 May 2024 00:00:00 +0530 Thu, 06 Feb 2025 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752653 The HC held that Section 147 reassessment proceedings were invalid as they were based on change of opinion rather than reason to believe. The assessee had fully disclosed interest transactions in the original assessment. The AO had consciously examined and treated interest paid/received as capital items instead of revenue items after applying his mind. The revenue's subsequent attempt to tax interest receipt as revenue was merely a change of opinion, not grounds for reopening under Section 147. The tribunal correctly set aside the reassessment proceedings in favor of the assessee. Case-Laws Income Tax Mon, 06 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752653