https://www.taxtmi.com/caselaws?id=773892 ITAT Mumbai quashed reassessment proceedings under section 147, ruling that AO's action constituted mere change of opinion without tangible material. The tribunal held that reassessment requires fulfillment of specific conditions and tangible evidence of income escapement, not review of original assessment. Since assessee had made proper disclosures in audited financial statements complying with accounting standards, and AO failed to produce new material justifying reopening, the proceedings were deemed abuse of power. Following Supreme Court precedent in CIT vs. Kelvinator, the tribunal emphasized that change of opinion cannot justify reopening assessments post-1989 amendments. Appeal allowed. en-us Thu, 26 Jun 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:43:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773892 ITAT Mumbai quashed reassessment proceedings under section 147, ruling that AO's action constituted mere change of opinion without tangible material. The tribunal held that reassessment requires fulfillment of specific conditions and tangible evidence of income escapement, not review of original assessment. Since assessee had made proper disclosures in audited financial statements complying with accounting standards, and AO failed to produce new material justifying reopening, the proceedings were deemed abuse of power. Following Supreme Court precedent in CIT vs. Kelvinator, the tribunal emphasized that change of opinion cannot justify reopening assessments post-1989 amendments. Appeal allowed. Case-Laws Income Tax Thu, 26 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773892