RAJESH YADAV PASHAM,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

ITA 1096/HYD/2025Status: DisposedITAT Hyderabad16 September 2026AY 2017-1812 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reopening of assessment was based on a 'change of opinion' as the AO relied on the same material available during the original assessment, without any fresh tangible evidence. Therefore, the reassessment order was quashed.

What were the facts?

The assessee claimed deductions for temporary registration and documentation charges. The Assessing Officer (AO) reopened the assessment, disallowing these expenses as the assessee failed to provide evidence and the claim was contrary to trade practices. The CIT(A) upheld the reopening and disallowance.

What were the issues?

Whether the reopening of assessment under Section 147 was valid when based on a change of opinion without fresh tangible material. The validity of disallowance of expenses claimed without sufficient evidence.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad

PER MANJUNATHA G., A.M :

This appeal filed by the assessee company is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [in short “NFAC”], Delhi, dated 22.04.2025, pertaining to the assessm

The order continues below.

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