https://www.taxtmi.com/caselaws?id=460449 The ITAT Raipur held that reopening of assessment under section 147 was invalid as it constituted a mere change of opinion. The AO used the same material that was available during the original assessment under section 143(3) for determining taxable long-term capital gains. Following the precedent in Rasalika Trading Investment Co., the tribunal ruled that using stale information without fresh material to establish allegations renders the assumption of jurisdiction under section 147 beyond legal authority. The reopening proceedings were quashed in favor of the assessee. en-us Mon, 17 Oct 2022 00:00:00 +0530 Fri, 24 Jan 2025 19:48:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460449 The ITAT Raipur held that reopening of assessment under section 147 was invalid as it constituted a mere change of opinion. The AO used the same material that was available during the original assessment under section 143(3) for determining taxable long-term capital gains. Following the precedent in Rasalika Trading Investment Co., the tribunal ruled that using stale information without fresh material to establish allegations renders the assumption of jurisdiction under section 147 beyond legal authority. The reopening proceedings were quashed in favor of the assessee. Case-Laws Income Tax Mon, 17 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460449