https://www.taxtmi.com/caselaws?id=765048 The ITAT Raipur held that while the notice u/s 143(2) was valid after the assessee e-verified their return following a s.148 notice, the reopening of assessment u/s 147 was invalid. The tribunal found that the successor AO reopened the concluded assessment based on the same facts previously considered during original assessment proceedings, constituting a mere change of opinion rather than fresh material. Following the SC precedent in Kelvinator of India, such reopening based solely on change of opinion is impermissible. The tribunal quashed the reopening while rejecting the assessee's challenge to the s.143(2) notice validity. en-us Mon, 20 Jan 2025 00:00:00 +0530 Thu, 23 Jan 2025 17:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765048 The ITAT Raipur held that while the notice u/s 143(2) was valid after the assessee e-verified their return following a s.148 notice, the reopening of assessment u/s 147 was invalid. The tribunal found that the successor AO reopened the concluded assessment based on the same facts previously considered during original assessment proceedings, constituting a mere change of opinion rather than fresh material. Following the SC precedent in Kelvinator of India, such reopening based solely on change of opinion is impermissible. The tribunal quashed the reopening while rejecting the assessee's challenge to the s.143(2) notice validity. Case-Laws Income Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765048