A.O Cannot act as a reviewing authorithy u/s 147 of Income Tax Act,1961

CA Prarthana Jalan Hon’ble Mumbai ITAT has in the case of DCIT V/s Century Textiles and Industries Ltd. held that The Assessing Officer has though power to re–assess but no power to review and if the concept of “change of opinion” is removed, then in the garb of the re–assessment, review of earlier orders would take place. The “change of opinion” is in–built test to check the abuse of power by the Assessing Officer. Thus, in such cases, the Assessing Officer can re–open the case only when there is “tangible material” coming on record having direct bearing with the e...