No “reason to believe” without new material – Mumbai ITAT quashes reopening based on mere reappraisal of old records

Jaydeep Construction Vs ITO (ITAT Mumbai) No “reason to believe” without new material – Mumbai ITAT quashes reopening based on mere reappraisal of old records In a significant ruling, the Mumbai ITAT quashed reassessment proceedings initiated u/s 147 after holding that the AO had reopened the completed scrutiny assessment merely on the basis of a reappraisal of existing records, without any new or tangible material coming into possession after completion of original assessment. The assessee, a construction firm following the Project Completion Method, had originally undergone scrutin...