Change of Opinion: ITAT Pune Quashes Reassessment; Section 68 & 40(a)(ia) Additions Fail

Vatsalabai Kabhari Deore Vs ITO (ITAT Pune) ITAT Pune Quashes Reassessment as Change of Opinion: Section 68 & 40(a)(ia) Additions Fail Without New Tangible Material The Pune Bench of the ITAT allowed the appeal of the assessee for AY 2011-12 by quashing the reassessment proceedings initiated under sections 147/148, holding that the reopening was based purely on a change of opinion and not on any new tangible material. The Tribunal noted that the original assessment had been completed under section 143(3) after detailed enquiries into unsecured loans received from relatives and interest pai...