Reassessment u/s 147 on Mere Change of Opinion Invalid: ITAT

The ITAT ruled that reassessment under Section 147 of the Income Tax Act based on a mere change of opinion is invalid. The tribunal emphasized that reassessment requires new tangible material or information. This decision protects taxpayers from arbitrary reassessments based on subjective views. It reinforces the legal principle that tax authorities cannot initiate reassessment simply by altering their opinion on the same facts. This ensures fairness and prevents unwarranted scrutiny of tax returns.