Reassessment Under Section 147 Quashed: Reopening Based on Change of Opinion Without New Material Invalid

The ITAT quashed reassessment proceedings initiated under s.147 for five assessment years, finding the AO's reopening was based on mere change of opinion rather than new tangible material. The Tribunal noted that information regarding profits from sales made on behalf of UBL had been disclosed in Notes to Accounts during regular assessment proceedings. The reopening was primarily influenced by audit objections and the Chamundi Winery case, demonstrating the AO lacked independent judgment. On merits, the ITAT concurred with the CIT(A)'s determination that the appellant functioned solely as a contract manufacturer for UBL, entitled only to reimbursement of expenses and bottling charges, with UBL being the de facto earner of income from manufacture and sale of liquor. .....

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