Reassessment on Dropped Audit Objection or Borrowed Satisfaction is Invalid

Viramgam Mahesana Project Limited Vs ACIT (ITAT Delhi) No Second Innings for dropped Audit Objection -Borrowed Satisfaction backfires – Change of Opinion not permissible – Reopening held invalid by ITAT Delhi Delhi ITAT has quashed a reassessment initiated solely on the basis of a previously dropped audit objection, holding that the action amounted to a mere change of opinion & was thus invalid. Assessee, Viramgam Mahesana Project Ltd., was set up as a Special Purpose Vehicle for converting the Viramgam–Mahesana meter gauge railway track into broad gauge on a Build–Own–Transf...