Reassessment u/s. 148 based on mere change of opinion is impermissible in law

DCIT Vs Sharada Erectors Private Limited (ITAT Pune) ITAT Pune held that reopening of assessment under section 148 of the Income Tax Act based on audit objection is merely change of opinion and the same is impermissible in law. Accordingly, notice issued u/s. 148 is not valid and is liable to be quashed. Facts- Post assessment u/s. 143(1), AO after analysis of the objections raised by the Revenue Audit Party held that the proportionate interest expenses of Rs.6,60,53,791/-cannot be allowed as deduction as per provisions of section 36(1)(iii) of the Act. He, therefore, issued a show cause noti...