Assessment Based On Change of Opinion Is Void Ab Initio

SJM International Ltd. Vs DCIT (ITAT Delhi) The conclusion of the Assessing Officer at the end of the reasons recorded as noted above is contradictory. In the first two lines, the Assessing Officer has recorded the finding that the sum of Rs.2,35,00,000/- has escaped assessment but in the last two lines, he has recorded that the case is being reopened to verify the genuineness, identification and creditworthiness of the aforesaid transactions. Any satisfaction with regard to escapement of income or otherwise can be recorded only after the verification of genuineness, identification and creditw...