AO had no power to review but having power to re-assess

Sanjit Jitendranath Biswas Vs ITO (ITAT Surat)  Conclusion: AO had no power to review; he had the power to re-assess. Reassessment was not justified in case  there was no “tangible material” found to come to the conclusion that there was escapement of income from assessment. Held: AO had reopened the assessment of assessee. Assessee contended that the reopening of assessment was arbitrary and based on mere change of opinion as the issues of reopening were duly covered in the original assessment order u/s 143(3). From the original assessment order u/s 143(3), it was cleared that receipts ...