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“change of opinion”

ReassessmentSection 147Section 1472,292 judgments

The decision most relied on for change of opinion is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on change of opinion

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

CIT v. SFIL Stock Broking Ltd.
325 ITR 285 · 2010 · High Court
243
citing judgments

Reassessment proceedings under Section 147 are invalid and void ab initio if initiated based on 'borrowed satisfaction' without the Assessing Officer's independent application of mind, or merely on documents already available on record without fresh tangible material.

Judgments citing change of opinion

ITO Ward 4(1), Kolkata vs. Tribute Trading and Finance Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 11/KOL/2025[2013-14]Status: DisposedITAT Kolkata21 Apr 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(2)Section 148

were submitted and assessed by DCIT, Circle-5(2), Kolkata during original assessment, so reassessment cannot be sustained on the basis of only change of opinion. He has challenged the reasons for reopening by citing a decision passed by the Hon’ble Supreme Court in the case of Yogendrakumar Gupta

DCIT 2 2 1, Mumbai vs. Yes Bank Limited, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 992/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent

For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B

ACIT, (2010) 323 ITR 54 (Bom), where the Hon’ble Bombay High Court held that reassessment was unsustainable if based merely on a change of opinion in the absence of tangible material. 5. On merits, the Ld. AR submitted that the assessee, Yes Bank Ltd., was placed under a moratorium

Innocent Infrastructure Private Limited, Mumbai vs. ITO Ward 12(2)(4), Mumbai

ITA 1236/MUM/2025[2014-15]Status: DisposedITAT Mumbai21 Apr 2025AY 2014-15

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 143(3)Section 147Section 243(3)Section 250Section 254(1)

holding that the initiation of reassessment proceedings u/s 147 of the Act was bad in law as it was based on mere change of opinion because all relevant details relating to the impugned unsecured loan were available with the Ld. A.O. at the time of the original scrutiny assessment proceedings ... addition in the assessment order passed on 18.12.2016. Thus, the reopening which was based on third party information was nothing but a change of opinion. It is settled law that the issue on which the AO made verification of fact, accepted in scrutiny, cannot be reopened. Otherwise

Yes Bank Limited, Mumbai vs. Additional Commissioner of Income Tax (Appeals), Panchkula

In the result, the appeal of the assessee bearing ITA No

ITA 1093/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent

For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B

ACIT, (2010) 323 ITR 54 (Bom), where the Hon’ble Bombay High Court held that reassessment was unsustainable if based merely on a change of opinion in the absence of tangible material. 5. On merits, the Ld. AR submitted that the assessee, Yes Bank Ltd., was placed under a moratorium

Hariram Hospital, Alwar vs. PCIT, Alwar

In the result, the appeal of the assessee is allowed

ITA 1535/JPR/2024[2019-20]Status: DisposedITAT Jaipur17 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1535/JPR/2024 निर्धारणवर्ष / Assessment Year: 2019-20 Hariram Hospital Bye Pass Road Hariram Hospital Bhiwadi, Alwar – 310 019 (Raj) बनाम Vs. The Pr.CIT (Central) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAFFH 5746 M अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Himanshu Goyal, CA राजस्व की ओरसे /Revenue by: Mrs. Alka Gautam, CIT-DR सुनवाई की तारीख / Da

For Appellant: Shri Himanshu Goyal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 263

caused any prejudice to the interest of revenue. (b) That the invocation of Section 263 is based on a mere change of opinion, which is impermissible under the law. The AO had conducted enquiries, examined the facts and formed a plausible view and the ld. PCIT’s disagreement with this ... Assessing officer is not erroneous but the action 13 HARIRAM HOSPITAL, ALWAR VS PCIT (CENTRAL), JAIPUR now initiated is just a change of opinion hence cannot be subject to the revision u/s 263 of the Income Tax Act 1961 The A.R further placed reliance on the decisions as under

Indo Pacific Finlease Ltd, Chandigarh vs. PCIT- Chandigarh 1, Chandigarh

In the result, both the appeals are filed by the

ITA 449/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh16 Apr 2025AY 2015-16

Bench: Shrilaliet Kumar & Shri Krinwant Sahayआयकर अपील सं . / I.T.A. Nos.448 & 449/Chd/2024 निर्धारणवर्ष / Assessment Years: 2014-15 & 2015-16

For Appellant: Sh. Ashok Goel, C.AFor Respondent: Sh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

assessee specifically raised the point of jurisdiction to reopen the assessment, contending that the notice of reopening was prompted by a mere change of opinion. The AO rejected plea of the assessee but the AAC accepted this ground and also held the reassessment to be bad in law on jurisdictional

Indo Pacific Finlease Ltd, Chandigarh vs. PCIT Chandigarh 1, Chandigarh

In the result, both the appeals are filed by the

ITA 448/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh16 Apr 2025AY 2014-15

Bench: Shrilaliet Kumar & Shri Krinwant Sahayआयकर अपील सं . / I.T.A. Nos.448 & 449/Chd/2024 निर्धारणवर्ष / Assessment Years: 2014-15 & 2015-16 Vs Pcitchandigarh 1, Chandigarh Indo Pacific Finlease Ltd., Sco-98-99, Sector 34 Sub City Centre, Chandigarh 160002 स्थायीलेखासं./Panno. Aaaci2176E अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By : Sh. Ashok Goel, C.A. Revenue By : Sh.Rohit Sharma, Cit-D.R. Date Of Hearing :19.03.2025 Date Of Pronouncement ;16/04/2025 Physical Hearing Order Per Laliet Kumar, J.M.: Both The Appeals Are Being Filed By The Assessee, Feeling Aggrieved By The Order Passed By The Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 Dated 28.03.2024& 23.03.2024 U/S 263 For The Assessment Years: 2014-15& 2015-16. 2. The Assessee Has Raised The Common Grounds Of Appeal In Ita Nos.448 & 449/Chd/2024 As Under:

For Appellant: Sh. Ashok Goel, C.AFor Respondent: Sh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

assessee specifically raised the point of jurisdiction to reopen the assessment, contending that the notice of reopening was prompted by a mere change of opinion. The AO rejected plea of the assessee but the AAC accepted this ground and also held the reassessment to be bad in law on jurisdictional

Grade One Events Pvt. Ltd., Ghaziabad vs. DCIT, Circle- 1, Ghaziabad

In the result, the captioned appeals filed by the assessees are allowed

ITA 1831/DEL/2018[2012-13]Status: DisposedITAT Delhi16 Apr 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

original assessment proceeding and no adversities were observed in such regard. Therefore, order passed u/s 263 of the act is pure example of 'change of opinion', and thereby, said order deserves to be annulled being illegal and invalid. 5. That the Ld. Pr. CIT had erred in interfering with original ... deserves to be dropped. 5. Further, impugned invocation of provisions of section 263 of the act in the impugned matter would tantamount to change of opinion' being considering all relevant documentary evidences available on record, the then assessing officer had not drawn any adverse inference but without bringing on record

Bses Yamuna Power Ltd, Delhi vs. ACIT, Circle-5(1), New Del;Hi

The appeal of the assessee is allowed on legal issues

ITA 4853/DEL/2017[2008-09]Status: DisposedITAT Delhi16 Apr 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

erred on facts and in law in not appreciating that proceedings under section 147 of the Act were initiated on a mere change of opinion without formation of reasonable belief regarding escapement of income, which is sine-qua-non for assumption of valid jurisdiction 3.2. That the CIT(A) erred ... ground of appeal No. 3 to 3.4, assessee has challenged the order u/s 147 / 143(3) as passed without jurisdiction, mere change of opinion and barred by limitation thus bad in law and void-ab- initio. 11. Before us, the ld. AR argued that the assessment in the case

Bses Yamuna Power Ltd., New Delhi vs. DCIT, Circle- 5(1), New Delhi

The appeal of the assessee is allowed on legal issues

ITA 4852/DEL/2017[2007-08]Status: DisposedITAT Delhi16 Apr 2025AY 2007-08

Bench: Shri Anubhav Sharma & Shri Manish Agarwalbses Rajdhani Power Ltd., Dy. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd., Asst. Cit, Bses Bhawan, Cicle-5(1), Nehru Place, Vs. New Delhi. New Delhi-110019 Pan-Aagcs3187H (Appellant) (Respondent) Bses Yamuna Power Dy. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Bses Rajdhani Power Ltd. & Ors Vs. Acit Bses Yamuna Power Asst. Cit, Limited, Cicle-5(1), Shakti Kiran Building, Vs. New Delhi. Karkardoooma, Delhi-110092 Pan-Aagcs3187H (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Sh. Deepesh Jain, Adv. & Sh. Shivam Gupta, Ca Department By Mr. Javed Akhtar, Cit-Dr Date Of Hearing 20/02/2025 Date Of Pronouncement 16/04/2025 O R D E R

Section 143(3)Section 147Section 148Section 154Section 250

erred on facts and in law in not appreciating that proceedings under section 147 of the Act were initiated on a mere change of opinion without formation of reasonable belief regarding escapement of income, which is sine-qua-non for assumption of valid jurisdiction 3.2. That the CIT(A) erred ... ground of appeal No. 3 to 3.4, assessee has challenged the order u/s 147 / 143(3) as passed without jurisdiction, mere change of opinion and barred by limitation thus bad in law and void-ab- initio. 11. Before us, the ld. AR argued that the assessment in the case

Sh. Rajesh Kakkar, Karnal vs. Pr. CIT, Karnal

The appeal is allowed

ITA 823/DEL/2016[2011-12]Status: DisposedITAT Delhi16 Apr 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2013-14 Sigma Paradise, Vs Dcit, Km-78, Kavi Nagar, Ward 2(2)(1), Ghaziabad, Ghaziabad. Uttar Pradesh – 201 002. Pan:Aazfs9643L (Appellants) (Respondents) Assessee By : Shri Rajiv Khandelwal, Ca; & Shri Gagan R. Khandelwal & Shri Jaind Kumar Jaiswal, Advocates Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 18.09.2025 Date Of Pronouncement : 26.11.2025

For Appellant: Shri Rajiv Khandelwal, CA; &For Respondent: Shri Manish Gupta, Sr. DR
Section 11Section 143(3)Section 147Section 148Section 4Section 50CSection 6

proceedings the appellant relied on certain case laws in its submission with regard to its contention that the reopening was based on a change of opinion by the AO since, the appellant’s case had already been scrutinized u/s 143(3) prior to the reopening. It claimed that valuation ... Delhi High Court in the case of Usha International Ltd. [2012] 348 ITR 485 (Del.) had examined in detail as to what constitutes change of opinion. If a subject-matter, entry or claim/deduction is not examined by an Assessing Officer, it cannot be presumed that he must have examined

M/S Godfrey Phillips India Ltd, Mumbai vs. The Assessing Officer, National Faceless Assessment Centre, Delhi/ Circle1(3)(1), Mumbai

In the result, the appeal filed by the assessee is partly

ITA 1218/MUM/2024[2015-16]Status: DisposedITAT Mumbai15 Apr 2025AY 2015-16

Bench: Ms. Padmavathy S. & Shri. Raj Kumar Chauhan

Section 135Section 143(1)Section 143(2)Section 143(3)Section 147(1)Section 148Section 151Section 250Section 80G

absence of any material, is bad in law and void. Thirdly, reopening has been done on the change of opinion only and the same is bad in law and contrary to the settled principle of law. Fourthly, reopening is bad in law because approval of Principal CIT was obtained mechanically ... material before the ld. AO and that it was a case of change of opinion on the part of the ld. AO. . It is also submitted that the ld. PCIT approval has been obtained mechanically and accordingly the opening of assessment is bad in law since the due process

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 1275/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Apr 2025AY 2012-13
For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 129Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 147Section 148Section 153ASection 2(22)(e)

view of above discussion the contention of the assessee in this regard are not found to be acceptable. 4.7.2 There is no change of opinion and on the basis of audit objection the case can be reopened The appellant has stated that notice u/s 148 cannot be issued ... basis of opinion and suggestion provided by the audit. The claim of change of opinion is not found to be correct on the facts as no opinion was formed by the AO during the original assessment proceedings on the issue of deemed dividend. The appellant failed to establish that

Tuff Tubes Orissa Private Limited, Jankia, Khordha vs. Deputy Commissioner of Income Tax, Circle-1(2), Bhubaneswar

ITA 52/CTK/2025[2012-13]Status: DisposedITAT Cuttack09 Apr 2025AY 2012-13

Bench: Shri George Mathan & Shri Rajesh Kumar

Section 148Section 250

disposed of by an order dated 15.02.2022 quashing the said notice u/s. 148 on the ground that the reopening was on a change of opinion. It was a submission that during the pendency of the Writ Petition before the Hon'ble jurisdictional High Court another notice u/s. 148 came

Kilamcheti Badri Narayan Subudhi, Bhubaneswar vs. ITO, Phulbani Ward, Phulbani

In the result, the appeal of the assessee is allowed

ITA 508/CTK/2024[2013-14]Status: DisposedITAT Cuttack09 Apr 2025AY 2013-14

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2013-14

For Appellant: Shri P. K. Mishra, AdvocateFor Respondent: Shri S. C. Mohanty, Sr. DR
Section 143(3)Section 148Section 250Section 44A

only for the purpose of change of rate of percentage of profit, the Assessing Officer has done the reopening which clearly was the change of opinion. It was the submission that reopening cannot be done on the basis of change of opinion. 5. In reply, the Ld. CIT, DR submitted ... been estimated in the original assessment order and in the reopened assessment order. This is not permissible as it is only a change of opinion. This being so, the reopening of the assessment as done by the Assessing Officer by issuing notice u/s. 148 is held

M. Natesan, Karur vs. ITO, Ward-1, Karur

In the result, all the appeals t, all the appeals stand allowed

ITA 2765/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

course of original according to him, was already examined in the course of original assessment for AY 2013 assessment for AY 2013-14, changed his opinion and formed a belief that and formed a belief that the assesses had failed to disclose fully and truly the investments made had failed ... Later on however, the AO’s successor is required to be scrutinized. Later on however, the AO’s successor is noted to have changed his opinion changed his opinion and issued notice u/s 148 of the Act on and issued notice u/s 148 of the Act on 26.03.2019 beyond four

R.Easwaramoorthy, Karur vs. ITO, Ward-1, Karur

In the result, all the appeals t, all the appeals stand allowed

ITA 2697/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

course of original according to him, was already examined in the course of original assessment for AY 2013 assessment for AY 2013-14, changed his opinion and formed a belief that and formed a belief that the assesses had failed to disclose fully and truly the investments made had failed ... Later on however, the AO’s successor is required to be scrutinized. Later on however, the AO’s successor is noted to have changed his opinion changed his opinion and issued notice u/s 148 of the Act on and issued notice u/s 148 of the Act on 26.03.2019 beyond four

S. Easwaramoorthy, Karur vs. ITO, Ward-1, Karur

ITA 2696/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 133A

appraisal of the impounded survey material, which according to him, was already examined in the course of original assessment for AY 2013-14, changed his opinion and formed a belief that the assesses had failed to disclose fully and truly the investments made on the construction of the polytechnic college ... assessee for AY 2012-13 was required to be scrutinized. Later on however, the AO's successor is noted to have changed his opinion and issued notice u/s 148 of the Act on 26.03.2019 beyond four years from the end of the relevant assessment year, on the basis

S. Easwaramoorthy, Karur vs. ITO, Ward-1, Karur

In the result, all the appeals t, all the appeals stand allowed

ITA 2695/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

course of original according to him, was already examined in the course of original assessment for AY 2013 assessment for AY 2013-14, changed his opinion and formed a belief that and formed a belief that the assesses had failed to disclose fully and truly the investments made had failed ... Later on however, the AO’s successor is required to be scrutinized. Later on however, the AO’s successor is noted to have changed his opinion changed his opinion and issued notice u/s 148 of the Act on and issued notice u/s 148 of the Act on 26.03.2019 beyond four

K. Paramasivam, Karur vs. ITO, Ward-1, Karur

ITA 2694/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 133A

appraisal of the impounded survey material, which according to him, was already examined in the course of original assessment for AY 2013-14, changed his opinion and formed a belief that the assesses had failed to disclose fully and truly the investments made on the construction of the polytechnic college ... assessee for AY 2012-13 was required to be scrutinized. Later on however, the AO's successor is noted to have changed his opinion and issued notice u/s 148 of the Act on 26.03.2019 beyond four years from the end of the relevant assessment year, on the basis