Without any supporting material A.O. cannot substitute market value

Brief of the Case ITAT Mumbai held in the case of DCIT v. Rama Capital and Financial Services Ltd.  that without any substantive ground reopening cannot be done on the basis of change of opinion. It Further held that without any supporting material, the A.O. cannot substitute market value. Summary of the Case In the present facts of the case there are two issues which are as follows: Issue of reassessment Assessment was reopened u/s 147 to bring to tax claim of finance charges by the assessee, to disallow interest claimed by assessee for diversion of interest bearing activities and loss clai...