Change of opinion not base for reassessment proceedings

Ambarnuj Finance And Investment Pvt. Ltd Vs DCIT (Delhi High Court) Delhi high court held that there was no new/ fresh material before AO to initiate reassessment proceedings, accordingly, mere change of opinion cannot form the basis for initiating reassessment proceedings Facts- During scrutiny assessment, AO disallowed the write off the ‘bad debt’ and made an addition to income of Rs. 30,00,152/- raising demand of Rs. 5,53,839/-. Being eligible, the assessee availed benefit of Direct Tax Vivad Se Vishwas Scheme (DTVSV). However, via e-mail it was informed to the assessee that there was a...