Reassessment Invalid Due to Change of Opinion on Same Facts: ITAT Mumbai

Omkara Diamonds Exports Private Limited Vs DCIT (ITAT Mumbai) Summary: In this case, the Tribunal examined whether a second reassessment under Section 147 could be initiated on the same set of facts already scrutinized and concluded in earlier proceedings. The assessee’s case had originally been reopened based on alleged bogus purchases, leading to an addition that was progressively reduced through appellate stages and ultimately finalized at 1.75%. Despite this finality, the Assessing Officer initiated a second reassessment using identical material, this time proposing a 100% disallowance. ...