Reassessment u/s 147 not permissible merely on change of opinion: ITAT

Brief of the Case ITAT Mumbai held In the case of ACIT vs. Reliance Industrial Infrastructure Ltd. that on perusal of the reasons recorded by AO for initiating the re-assessment proceedings, it is clear that the said details were available while completing the assessment u/s 143(3). Further, the AO has reopened the assessment after expiry of four years from the end of the relevant assessment year. Hence it is imperative on the part of the assessing officer to show that the conditions specified in the first proviso to sec. 147 are complied with. However, the AO has failed to show that there was...