Reassessment not Change of Opinion if original assessment not involve any formation of opinion

Sunny Tarunkumar Doshi Vs ITO (ITAT Ahmedabad)

Conclusion: AO had rightly reopened assessee’s case as there was no change of opinion but all the aspects should have been taken into consideration by AO under proceedings related to Section 143(1) and assessee was admitting that the cancelation had not been done but was under process, but no evidence had been filed by assessee as regards cancellation of sale deed. Therefore, AO rightly made addition of Rs.69,49,250/- as assessee’s income from undisclosed sources (50% of the stamp duty value of the properties).

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