Reopening quashed as matter already considered during original assessment: ITAT Cuttack

Rajeswar Thakur Vs ACIT (ITAT Cuttack) ITAT Cuttack held that reassessment proceedings cannot be sustained since issue already considered during original assessment by AO and hence reopening amounts to change of opinion. Accordingly, order quashed. Facts- Assessee has preferred the present appeal mainly contesting that the reopening was in fact challenge to the agriculture income declared by the assessee. It was the submission that the reopening was based on change of opinion. The Assessing Officer in the original proceedings had considered the agricultural income of the assessee. The explanat...