Reassessment u/s. 147 without any fresh and new material is invalid

RNG Construction Co. Vs Addl. Jt. Dy. Asstt. ITO (ITAT Indore)

ITAT Indore held that reopening of assessment done by Assessing Officer under section 147 of the Income Tax Act, based on tax audit report already available during original assessment, without any fresh and new material is invalid and liable to be quashed.

Facts- Post completion of scrutiny assessment, the AO re-opened assessment u/s 147 through a notice dated 20.03.2020 u/s 148 after recording reasons. Finally, the AO completed re-opened assessment vide order dated 27.09.2021 re-determining tota

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