Reassessment u/s. 147 without any fresh material not sustainable: ITAT Raipur

Rahul Bajpai Vs ACIT (ITAT Raipur) ITAT Raipur held that reassessment proceedings under section 147 of the Income Tax Act without any fresh material, amounts to mere change of opinion, and hence the same is not sustainable in law. Facts- A.O based on information that while for the assessee had purchased a land situated at Talapara, Bilaspur vide a registered sale deed for a consideration of Rs.4,11,000/-, but the Fair Market Value (FMV) of the said property that was adopted by the stamp valuation authority was Rs.3.75 crore, thus, holding a conviction that the difference in the aforesaid value...