ITAT Mumbai: Reopening Invalid on Change of Opinion-No Fresh Material, Assessment Quashed

Mohammed Iqbal Khan Vs ACIT (ITAT Mumbai) The Mumbai ITAT held that reassessment proceedings initiated under Sections 147/148 are invalid where based solely on re-examination of already scrutinised facts, without any fresh tangible material. In this case, the Assessing Officer reopened the assessment based on information from the Investigation Wing regarding bank transactions. However, the Tribunal noted that the very same bank account and transactions had already been examined during the original assessment under Section 143(3), where full details were furnished by the assessee. The ITAT obse...