Reassessment u/s. 147 based solely on change of opinion is impermissible

Balajee Infratech & Constructions Pvt. Ltd Vs DCIT (ITAT Mumbai) ITAT Mumbai held that reopening of assessment under section 147 of the Income Tax Act impermissible since based solely on change of opinion without any new tangible material. Further, even on merits royalty payment represents a legitimate business expenditure allowable u/s. 37(1). Facts- The present appeal has been preferred by the assessee against the order dated 24th January 2025 passed by Addl./Joint Commissioner of Income Tax (Appeals) pertaining to the assessment year 2012–13, arising out of the assessment framed u/s....