Reopening cannot be done in a mechanical manner & on a mere change of opinion

Standard Builders Vs ACIT (ITAT Chennai)

ITAT held that reopening could not be done in a mechanical manner and on a mere change of opinion. Further, in case of reopening beyond 4 years, the revenue must allege that there was failure on the part of the assessee to disclose material facts. We find that the impugned order is very cryptic on the issue of reopening and reassessment proceedings have been justified merely by observing that the notice u/s 148 was issued as per law and AO had followed the due procedure while completing the reassessment proceedin

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