Second Reopening u/s 147 Quashed as Change of Opinion—Section 54F Deduction Cannot Be Revisited Without New Material

Adhi Kumara Guru Vs DCIT (ITAT Chennai) The appeal before the Income Tax Appellate Tribunal, Chennai Bench, concerned the validity of reassessment proceedings initiated for Assessment Year 2014–15. The assessee challenged the order of the Commissioner of Income Tax (Appeals) which had upheld a reassessment order passed under section 143(3) read with section 147 of the Income-tax Act, 1961. The assessee had filed the return of income on 19.02.2015, declaring long-term capital gains arising from the sale of immovable properties. During the year, the assessee derived long-term capital gains of ...