https://www.taxtmi.com/caselaws?id=775926 The ITAT Ahmedabad held that the reopening of assessment under section 147 was invalid as the AO's notice lacked specificity regarding transactions with certain parties. The assessee had responded to notices under sections 142(1) and 143(2), clarifying that the questioned transactions were unrelated to the parties named in the reopening. The AO's reliance on a differing opinion during section 263 proceedings was deemed a mere second opinion, insufficient to justify revision. Consequently, the invocation of section 263 was held unjustified, and the assessee's appeal was allowed. en-us Wed, 01 Jan 2025 00:00:00 +0530 Sat, 02 Aug 2025 07:24:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775926 The ITAT Ahmedabad held that the reopening of assessment under section 147 was invalid as the AO's notice lacked specificity regarding transactions with certain parties. The assessee had responded to notices under sections 142(1) and 143(2), clarifying that the questioned transactions were unrelated to the parties named in the reopening. The AO's reliance on a differing opinion during section 263 proceedings was deemed a mere second opinion, insufficient to justify revision. Consequently, the invocation of section 263 was held unjustified, and the assessee's appeal was allowed. Case-Laws Income Tax Wed, 01 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775926