ITAT Ahmedabad Quashed Reassessment for Opinion Change on TDS Reconciliation

Parvindar Indar Singh Vs ACIT (ITAT Ahmedabad) Reopening Beyond Four Years Quashed: Change of Opinion Cannot Justify Reassessment The Ahmedabad Bench of the Income Tax Appellate Tribunal (ITAT) quashed the reassessment proceedings initiated under section 147 beyond four years, holding that the reopening was based on a mere change of opinion and not on any failure by the assessee to disclose material facts. The assessee, a cardiologist following the cash system of accounting, had fully disclosed all particulars during the original scrutiny assessment completed under section 143(3). The Tribunal...