Reopening of assessment without any fresh tangible material unsustainable

Nainudevi A. Prajapati Vs ITO (ITAT Ahmedabad)

ITAT Ahmedabad held that reopening of assessment under section 147 of the Income Tax Act initiated on a mere change of opinion without any fresh tangible material unsustainable in law.

Facts- The assessee filed return of income u/s. 139(1) of the Act declaring total income of ₹ 4,50,177/-. The case was selected for scrutiny and assessment order u/s. 143(3) of the Act was passed on 30-12-2011, determining the total income at

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