https://www.taxtmi.com/caselaws?id=460562 The ITAT Ahmedabad dismissed the Revenue's appeal challenging the CIT(A)'s decision invalidating the reopening of assessment beyond four years. The tribunal held that the AO lacked jurisdiction to review his own order and could only rectify apparent mistakes under section 154. Following the Delhi HC precedent in Kelvinator case, the tribunal ruled that without new tangible material or failure by the assessee to disclose income, reopening assessment after four years constitutes merely a change of opinion, making it invalid in law. en-us Fri, 20 Oct 2023 00:00:00 +0530 Fri, 31 Jan 2025 18:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460562 The ITAT Ahmedabad dismissed the Revenue's appeal challenging the CIT(A)'s decision invalidating the reopening of assessment beyond four years. The tribunal held that the AO lacked jurisdiction to review his own order and could only rectify apparent mistakes under section 154. Following the Delhi HC precedent in Kelvinator case, the tribunal ruled that without new tangible material or failure by the assessee to disclose income, reopening assessment after four years constitutes merely a change of opinion, making it invalid in law. Case-Laws Income Tax Fri, 20 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460562