https://www.taxtmi.com/caselaws?id=760283 ITAT Chennai held that reopening of assessment was invalid where AO attempted to reassess interest income classification without new tangible material. The race club assessee had originally filed returns claiming business loss, which underwent scrutiny assessment under section 143(3) and was partly allowed by CIT(A). AO subsequently reopened assessment under section 148 on same issues using identical materials from original assessment records. ITAT ruled that mere change of opinion cannot justify reopening concluded assessments, citing SC precedents in Calcutta Discount Co. and Kelvinator cases. Since no fresh material existed beyond what was already considered, the reopening constituted impermissible review disguised as reassessment. Assessee's appeal was allowed. en-us Wed, 16 Oct 2024 00:00:00 +0530 Fri, 18 Oct 2024 09:15:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760283 ITAT Chennai held that reopening of assessment was invalid where AO attempted to reassess interest income classification without new tangible material. The race club assessee had originally filed returns claiming business loss, which underwent scrutiny assessment under section 143(3) and was partly allowed by CIT(A). AO subsequently reopened assessment under section 148 on same issues using identical materials from original assessment records. ITAT ruled that mere change of opinion cannot justify reopening concluded assessments, citing SC precedents in Calcutta Discount Co. and Kelvinator cases. Since no fresh material existed beyond what was already considered, the reopening constituted impermissible review disguised as reassessment. Assessee's appeal was allowed. Case-Laws Income Tax Wed, 16 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760283