Change of opinion not base for reassessment proceedings

Ambarnuj Finance And Investment Pvt. Ltd Vs DCIT (Delhi High Court)

Delhi high court held that there was no new/ fresh material before AO to initiate reassessment proceedings, accordingly, mere change of opinion cannot form the basis for initiating reassessment proceedings

Facts- During scrutiny assessment, AO disallowed the write off the ‘bad debt’ and made an addition to income of Rs. 30,00,152/- raising demand of Rs. 5,53,839/-.

Being eligible, the assessee a

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