ITAT Kolkata Quashed Reopening Because It Was Based on Mere Change of Opinion

Electronics Industry Development Corporation Limited Vs CIT (Appeals) (ITAT Kolkata) In Electronics Industry Development Corporation Limited Vs CIT (Appeals), the appeals before the ITAT Kolkata arose from an order dated 29.05.2024 passed under Section 250 of the Income Tax Act, 1961 by the Commissioner of Income Tax (Appeals), NFAC, Delhi. Since both appeals involved the same assessee and common issues, they were disposed of through a consolidated order. The Tribunal first addressed ITA No. 1590/Kol/2024. The primary issue was whether reopening of assessment under Sections 147/148 was valid o...