No Change of Opinion When Issue Never Examined – ITAT Delhi Upholds Reopening

Jain Textile Industries Vs ACIT (ITAT Delhi) Delhi ITAT dismissed Assessee’s appeal, holding that reopening u/s 147 was valid as the issues of interest income & capitalisation of accessories were never examined in the original assessment & hence it was not a case of “change of opinion”. Assessee, a textile processor engaged in dyeing & printing, had filed its return declaring Nil income which was initially assessed u/s 143(3). Later, AO reopened the case u/s 147 after noticing that interest income of ₹5.17 lakh was omitted & ₹1.27 crore spent on accessories for boiler...