Reopening of assessment without any new tangible material is untenable in law

Ramamirtham Mangaladhevi Vs ITO (ITAT Chennai) ITAT Chennai held that reopening of assessment in absence of any failure on the part of the assessee to disclose material facts necessary for the assessment and without any new tangible material is untenable in law. Facts- The original return of income filed by the assessee was scrutinized u/s 143(3) on 19.03.2015. However, the case was reopened beyond 4 years from end of relevant assessment year and notice u/s 148 was issued on 26.03.2018. In the recorded reasons, as placed on page nos. 17 of the paper-book, Ld. AO alleged that Long Term Capital ...