Re-appreciation of seized material in subsequent proceedings by the AO is unjustified

CA Prarthana Jalan Hon’ble ITAT Agra in the case of ACIT V/s. Kalyani Chaturvedi held that Re-appreciation of seized material in subsequent proceedings by the AO is unjustified and quashed the Re-assessment Order. Hon’ble ITAT has held as under- All facts were all along were within the knowledge of the AO at original assessment stage, therefore, reappreciation of evidence at subsequent re-assessment proceedings is not permitted on mere change of opinion by subsequent AO. The re-assessment proceedings have been initiated again on similar issue and totally on identical facts regardin...