ITAT Mumbai: Second Reopening Based on Same Material Is Invalid-Change of Opinion Not Permissible

Vaibhav Dwarkanath Warekar Vs ITO (ITAT Mumbai) ITAT Mumbai: Second Reopening Based on Same Material Is Invalid-Change of Opinion Not Permissible The ITAT Mumbai held that a second reassessment on the same issue, without fresh material, amounts to mere change of opinion and is invalid in law, thereby quashing the reassessment. In this case, the assessee’s assessment was reopened twice based on alleged bogus purchase entries. In the first reassessment, income was estimated at 0.25% of turnover, which was upheld by appellate authorities. However, in the second reassessment, the AO again estima...