Audit Objection Can’t Reopen Past Assessment, U/s 148 Notice Quashed

ACIT Vs Chinraj Shanthi (ITAT Chennai) From Audit Note to Dead Notice: 148 Notice Struck Down by ITAT- Audit Objection Can’t Reopen Past: Change of Opinion Is Not ‘Reason to Believe’: Reassessment Quashed In ACIT, Central Circle (I/c), Salem Vs. Chinraj Shanthi, ITA No.2037/Chny/2025 & CO No.81/Chny/2025, AY 2012-13, order dated 31.12.2025, Chennai ITAT dismissed Revenue’s appeal & upheld quashing of reassessment initiated u/s 147 r.w.s. 148 beyond four years. Original assessment was completed u/s 143(3) on 14.11.2014. Subsequently, AO reopened assessment on 31.03.2019 alleging...