ITAT Hyderabad Quashes Reopening: No Second Bite on Gift Addition – Change of Opinion Not Allowed

Daya Shanker Tiwari Vs ITO (ITAT Hyderabad) No second bite- Tribunal blocks AO’s attempt to retax gift-Same Story, Same Facts- AO’s revisit of same facts held impermissible – Change of opinion cannot justify Reopening Original assessment was been completed u/s 143(3)  determining  the total income of Assessee at Rs.16,91,705 by making addition of Rs.5 lakhs u/s 69A  as explained money towards gift received from Sri Pradeep Tiwari  (PT). Subsequently, it was reopened u/s 147  for   escapement of on account of under- assessment of gift to the extent of Rs.6 lakhs received from S...