Madras HC Nixes Reassessment: Change of Opinion Cannot Justify Reopening

PCIT Vs Ramanathan Adaikalavan (Madras High Court) The Madras High Court dismissed the appeal of the Revenue & upheld the ITAT’s order quashing reassessment proceedings u/s 148. Assessee had filed his return u/s 139 along with the balance sheet & tax audit report u/s 44AB. In the original scrutiny assessment u/s 143(3), AO had examined the claim of long-term capital gains arising on sale of capital assets. Subsequently, the case was selected under CASS on the ground of “low capital gain vis-à-vis sale consideration”. A notice u/s 148 was issued, seeking to reopen the assessment....