Reassessment After Four Years Invalid for Change of Opinion: ITAT Chennai

Nagarajan Jaya Vs ITO (ITAT Chennai) Reassessment Beyond Four Years Held Invalid – ITAT Chennai (AY 2011–12) The Chennai Bench of the Income Tax Appellate Tribunal allowed the assessee’s appeal by holding that the reassessment initiated under section 147 after four years from the end of the relevant assessment year was invalid in law. The original assessment under section 143(3) had already examined the real-estate transactions and accepted the assessee’s disclosure of commission income at 3% on total turnover of ₹1.84 crore. The Tribunal held that once the entire reassessment order ...