Section 40A(3) Disallowance Set Aside in Invalid Reassessment

Pankaj Jindal Contractor Vs DCIT (ITAT Amritsar) Reopening After Four Years Quashed as Change of Opinion — Disallowance Under Section 40A(3) and Addition Under Section 68 Set Aside The Amritsar Bench of the ITAT allowed the assessee’s appeal in full and quashed the reassessment proceedings initiated under Sections 147/148 for A.Y. 2014-15, holding them to be invalid as a mere change of opinion. The assessee, a civil contractor, had originally been assessed under Section 143(3) after detailed scrutiny of cash expenses (machinery rent, carriage of material) and unsecured loans, with the AO m...