AdvertisementShikha Kedia Vs ITO (ITAT Hyderabad)Hyderabad ITAT Quashes Reassessment as Mere “Change of Opinion”: AO Cannot Reopen Scrutiny Assessment on Same Material Merely Because Audit Raises an ObjectionThe Hyderabad Bench of the Income Tax Appellate Tribunal, SMC-Bench, in ITA No. Original Scrutiny Assessment and Cash DepositsThe assessee had originally filed her return on 06.11.2017 declaring total income of ₹3,54,300. ITAT’s Findings on Change of OpinionThe Tribunal found that the facts relied upon for reopening were already available during the original scrutiny assessment. Section 148 Reopening Held InvalidThe Tribunal accordingly set aside the reopening by notice under Section 148 dated 30.03.2021 as invalid. In the absence of contrary material or facts, the Assessing Officer could not re-examine and re-verify the same evidence in reassessment.