Court Upholds Tribunal's Decision Quashing Reassessment; No New Evidence Found, Mere Change of Opinion Insufficient.

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....Reopening of assessment u/s 147 - The High Court dismissed the appeal filed by the revenue, affirming the decision of the Income Tax Appellate Tribunal (ITAT) that quashed the reassessment proceedings u/s 147 of the Income Tax Act, 1961. The court held that the reassessment proceedings were initiated based on a mere change of opinion and not on any new tangible material. The original assessment had already considered and decided on the nature of the interest paid and received, and the reassessment sought to reclassify these without any fresh evidence or rationale.....