Reopening Based Only on Change of Opinion Is Not Permissible: ITAT Chennai

Hitesh Kumar Prithviraj Kawad Vs DCIT (ITAT Chennai) The appeal in question concerns an individual assessee challenging the validity of reassessment proceedings and the denial of a deduction under Section 54F of the Income-tax Act, 1961, for the assessment year 2015-16. The original return of income was filed on 27 March 2016, declaring a total income of ₹99,75,750. The assessment under Section 143(3) was completed on 18 December 2017, determining income at ₹1,04,33,030. Subsequently, the Principal Commissioner of Income Tax (PCIT) issued a direction under Section 263 to revise the assessm...