Reassessment Based on Change of Opinion Invalid – ITAT Delhi Quashes Section 147 Action  

Uday Punj Vs DCIT (ITAT Delhi)

ITAT Delhi quashed the reassessment proceedings initiated against Uday Punj, holding that the reopening was invalid being based on a mere change of opinion. Assessee had originally filed his return declaring income of ₹43.04 lakh, which was assessed u/s 143(3) at ₹63.40 lakh. In that assessment, AO had examined the issue of set-off of speculative losses from AY 2007-08/2008-09 against current short-term capital gains, & accepted Assessee’s explanation.

Subsequently, AO reopened the case u/s 14

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