https://www.taxtmi.com/caselaws?id=314204 ITAT Kolkata quashed reassessment proceedings u/s 147 where AO added 1% commission income on share capital raised by assessee for facilitating accommodation entries. The original assessment u/s 143(3) had examined identical share capital details through s/133(6) notices to investors and assessed income at NIL. Despite reopening based on alleged accommodation entry information, AO made no addition for that reason but instead added estimated commission income on previously examined transactions. ITAT held this constituted impermissible change of opinion, making reassessment proceedings bad and illegal. Order allowed in favor of assessee. en-us Mon, 16 Oct 2023 00:00:00 +0530 Fri, 24 May 2024 06:26:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314204 ITAT Kolkata quashed reassessment proceedings u/s 147 where AO added 1% commission income on share capital raised by assessee for facilitating accommodation entries. The original assessment u/s 143(3) had examined identical share capital details through s/133(6) notices to investors and assessed income at NIL. Despite reopening based on alleged accommodation entry information, AO made no addition for that reason but instead added estimated commission income on previously examined transactions. ITAT held this constituted impermissible change of opinion, making reassessment proceedings bad and illegal. Order allowed in favor of assessee. Case-Laws Income Tax Mon, 16 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314204