Change of opinion or review while exercising Section 263 is not permitted

Jitendrakumari Dilavarsinhji Jadeja Vs PCIT (ITAT Ahmedabad) It is pertinent to note that the Assessing Officer in notice under Section 142(1) of the Act has asked the query not in general but specifically asked the details about the land purchased and sold along with sale deed and purchase deed. The reply of the assessee clearly shows that the assessee has given all the details in response to DVO’s calculation related to land and the indexation thereto. In fact, the Assessing Officer in reopening has categorically made finding and made addition to the extent of Rs.18,63,319/- on account of ...