https://www.taxtmi.com/caselaws?id=776976 ITAT MUMBAI - AT dismissed the revenue's appeal, upholding the CIT(A) that the second reassessment was invalid. The AO reopened assessment twice alleging the assessee was not beneficial owner, but relied on the same materials both times and introduced no new evidence; mere change of opinion cannot justify reopening under section 143(3). Applying higher-court ratio, the Tribunal found no basis to interfere and confirmed that the second reassessment was not permissible, resulting in dismissal of the revenue appeal. en-us Tue, 07 Jan 2025 00:00:00 +0530 Tue, 19 Aug 2025 15:12:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776976 ITAT MUMBAI - AT dismissed the revenue's appeal, upholding the CIT(A) that the second reassessment was invalid. The AO reopened assessment twice alleging the assessee was not beneficial owner, but relied on the same materials both times and introduced no new evidence; mere change of opinion cannot justify reopening under section 143(3). Applying higher-court ratio, the Tribunal found no basis to interfere and confirmed that the second reassessment was not permissible, resulting in dismissal of the revenue appeal. Case-Laws Income Tax Tue, 07 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776976