https://www.taxtmi.com/caselaws?id=777783 ITAT CHENNAI - AT quashed reopening under s.148 as a mere change of opinion, allowing the appeal. The Tribunal held AO had no fresh material to justify notice, noting the AO had earlier queried loan balances and applicability of s.2(22)(e) under s.142(1); the assessee furnished specific replies and detailed submissions and assessment u/s 143(3) was completed. Applying SC and HC precedents, the Tribunal found reopening improper and set aside the reassessment notice. en-us Mon, 13 Jan 2025 00:00:00 +0530 Fri, 05 Sep 2025 08:10:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777783 ITAT CHENNAI - AT quashed reopening under s.148 as a mere change of opinion, allowing the appeal. The Tribunal held AO had no fresh material to justify notice, noting the AO had earlier queried loan balances and applicability of s.2(22)(e) under s.142(1); the assessee furnished specific replies and detailed submissions and assessment u/s 143(3) was completed. Applying SC and HC precedents, the Tribunal found reopening improper and set aside the reassessment notice. Case-Laws Income Tax Mon, 13 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777783