Reopening cannot be done for Mistake committed by AO in Original Assessment

ITO Vs M/s. Epkon Associates (ITAT Kolkata) A perusal of the reasons recorded by the A.O. clearly shows that the assessment originally completed u/s 143(3) was reopened by him on the basis of the same set of facts and same material as were available with him at the time of completion of assessment originally u/s 143(3) and there was no new tangible material tht had come to his possession which formed the basis of reopening of assessment. At the time of hearing before us, the Ld. DR has not been able to dispute this position clearly evident from the reasons recorded by the A.O. He, however, ha...