https://www.taxtmi.com/caselaws?id=776091 The ITAT Chennai held that the reopening of assessment under section 147 beyond four years was invalid as the reasons for reopening were based on the same material already available during the original assessment under section 143(3). The AO did not possess any fresh tangible evidence to justify reopening, making it a mere change of opinion, which is impermissible under established precedent. Consequently, the reopening was quashed and the assessee's appeal was allowed. en-us Thu, 02 Jan 2025 00:00:00 +0530 Tue, 05 Aug 2025 07:54:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776091 The ITAT Chennai held that the reopening of assessment under section 147 beyond four years was invalid as the reasons for reopening were based on the same material already available during the original assessment under section 143(3). The AO did not possess any fresh tangible evidence to justify reopening, making it a mere change of opinion, which is impermissible under established precedent. Consequently, the reopening was quashed and the assessee's appeal was allowed. Case-Laws Income Tax Thu, 02 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776091