Ahmedabad ITAT Quashes Reassessment Beyond Four Years as Mere Change of Opinion; Deletes ₹1.33 Crore Disallowance Under Section 37(1)

Tipsons Stock Brokers Pvt. Ltd. Vs DCIT (ITAT Ahmedabad) Ahmedabad ITAT Quashes Reassessment Beyond Four Years as Mere Change of Opinion; Deletes ₹1.33 Crore Disallowance Under Section 37(1) The Ahmedabad ITAT allowed the assessee’s appeal by quashing the reassessment proceedings initiated under sections 147/148 and also holding, on merits, that the disallowance of ₹1.33 crore under section 37(1) was unsustainable. The Tribunal held that the reassessment, initiated beyond four years from the end of the relevant assessment year, was based solely on a reappraisal of material already av...