Reopening u/s. 148 quashed as tantamount to change of opinion: ITAT Surat

Nazar Impex Pvt. Ltd Vs ITO (ITAT Surat) ITAT Surat held that reopening of assessment under section 148 of the Income Tax Act without tangible material tantamount to change of opinion on the existing facts and the same is impermissible in law. Accordingly, appeal allowed and reopening quashed. Facts- Post completion of assessment u/s. 144 r.w.s. 153C, the case was reopened and it was found that the assessee had entered into transactions of Rs.5,44,66,359/- with M/s Rose Impex, a concern run and controlled by Bhanwarlal Jain group, which was providing accommodation entries of unsecured loan and...