Assessment u/s 147 cannot be Reopened based on Mere Change of Opinion: ITAT quashes Reassessment

The Ahmedabad ITAT ruled that reopening assessments under Section 147 of the Income Tax Act due to a mere change of opinion by the Assessing Officer (AO) is unlawful. The AO had previously reviewed and accepted the original assessment, which had allowed depreciation at a specific rate. Reopening the case simply to alter that depreciation rate from 60% to 25% was deemed a reassessment based solely on a change of opinion, which is not permissible under Section 147. The Tribunal emphasized that assessments cannot be reopened without concrete new evidence or valid reasons, and changes in interpretation do not justify reassessment. As a result, the reassessment order was quashed in favor of the taxpayer.