Reopening of assessment without tangible material is invalid

Indo Colchem Pvt. Ltd. Vs ACIT (ITAT Ahmedabad) ITAT Ahmedabad held that reopening of assessment u/s. 147 of the Income Tax Act after four years without any tangible material amounts to change of opinion and according the same is invalid and liable to be quashed. Facts- The assessee is a Private Limited Company engaged in manufacturing of Dyes and Dye intermediates. Regular assessment u/s. 143(3) was completed. Thereafter the case was reopened u/s. 148 on account of excess claim of additional depreciation for Fluidized Bed Furnace which was utilized to generate hot air by heat treatment and no...