Reopening of assessment based on mere change of opinion unsustainable: ITAT Delhi

Bhartiya Samruddhi Investments And Consulting Services Limited Vs ACIT (ITAT Delhi) ITAT Delhi held that mere change of opinion would not confer jurisdiction upon the Assessing Officer to reopen proceedings without anything further. Thus, reopening of assessment under section 147 of the Income Tax Act set aside. Facts- It was noted by the AO that expenditure of Rs. 91,47,928/- claimed as ‘sundry advances/ assets written off’ was debited to the Profit and Loss account. AO observed that the said expenditure being capital in nature should have been added back to the income of the assessee com...