Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.109/Ran/2019 (नििाारण वषा / Assessment Year :2012-2013) Shri Sanjog Prasad, Vs. Acit, Circle-3(1), H.No.493, B-Block, Sonari, Jamshedpur Jamshedpur-831011 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acupp 8930 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 23/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R This Appeal Has Been Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals), Jamshedpur, Dated 14.01.2019 Passed In First Appeal No.50/Jsr/2018-19 For The Assessment Year 2012- 2013. 2. The Assessee Has Raised The Following Grounds Of Appeal :- 1. For That The Assessment Being Completed U/S 147/143(3) Is Ab Initio Void & Illegal. The Subject Matter For The Initiation Of Proceeding U/S 147 Was Already Considered & Looked Into During The Course Of Scrutiny Assessment U/S 143(3). As Such, This Initiation Can Only Be Said To Be Change Of Opinion. As Such, Proceeding Being Initiated U/S 147 Is Ab Initio Void, Illegal & Fit To Be Deleted. 2. For That The Authorities Below Were Not Justified In Not Considering The Objection Raised By The Appellant Regarding The Initiation Of Proceeding U/S 147. There Was No Fresh Material Available On Record With The Ld. Ao To Suggest Any Escapement Of Income. As Such, The Proceeding Being Initiated Merely On Change Of Opinion Is Unjustified, Illegal & Fit To Be Deleted.

addition of Rs.66,300/- on 5 account of flat No.502, Syndicate Colony, Uliyan Kadma, Jamshedpur to the total income of the assessee as undisclosed income, therefore, it is a clear case of change of opnion. 12. On careful consideration of above rival submission, first of all, I may point out that the AO on 21.09.2017 recorded the following reasons