Reassessment u/s. 147 based on change of opinion without any fresh material not sustainable

ITO Vs HSG Propmart Private Limited (ITAT Delhi) ITAT Delhi held that re-assessment proceedings under section 147 of the Income Tax Act initiated due to change of opinion without having any fresh material on record is liable to be quashed. Accordingly, appeal of revenue dismissed. Facts- The Assessee is a Private Limited Company and engaged in the business as builders, consultants, civil engineers. The case was selected for Complete Scrutiny through CASS and the assessment u/s 143(3) of the Act was completed on 03.10.2017 with the acceptance of the returned loss of Rs. 7,86.370/-. Subsequently...