Reopening to assess Income under different head due to change of opinion is invalid

ACIT Vs. Shri Rajendra Bhararia (ITAT Visakhapatnam)

The assessee has received the remuneration from M/s Sampath Vinayaka Steels (P) Ltd and A.S.Steel City Chits (India) Pvt. Ltd. and offered the same as income from other sources. The assessee was admitting the said remuneration as income from other sources regularly. As observed from the order of the Ld. CIT(A) in the earlier year as well as in the subsequent year also, the assessee had admitted the remuneration received from the company as income from other sources, which

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