Change of Opinion without New Material: ITAT Raipur Quashes Reassessment

ITO Vs Bishambhar Dayal Agrawal (ITAT Raipur)

Income Tax Appellate Tribunal (ITAT), Raipur Bench, recently addressed procedural and substantive issues concerning the reopening of assessments under Section 147 of the Income Tax Act, 1961, in the case of ITO Vs Bishambhar Dayal Agrawal. A key preliminary issue involved the assessee’s right to challenge the jurisdiction assumed by the Assessing Officer (AO) for reopening the assessment, even without filing a cross-appeal or cross-objection, and despite not raising the issue before the Commissioner of

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