Mere Change of Opinion Cannot Justify Reopening: Reassessment Against PNB Quashed

DCIT Vs Punjab National Bank (ITAT Delhi) ITAT Delhi Upholds Quashing of Reassessment Against Punjab National Bank – Mere Change of Opinion Cannot Justify Reopening The original scrutiny assessment u/s 143(3) was completed on 27.02.2014. Later, AO issued notice u/s 148 on 22.09.2017 alleging that Assessee had failed to add provision for standard assets in computation of book profit u/s 115JB, resulting in escapement of income of Rs.35 crore. NFAC quashed reopening, holding that since assessment was reopened beyond four years from end of AY 2011-12, the proviso to sec 147 applied, requiring A...