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of <h1>Validity of reassessment order when deduction prohibited under Income-tax Act SLP dismissed, reopening barred by change of opinion</h1> Validity of reassessment where a deduction is prohibited under the Income-tax Act: reassessment cannot be sustained if it rests solely on a change of ... Validity of re-assessment order when the deduction claimed by the assessee is prohibited under the Income-tax Act - change of opinion - jurisdictional parameters for reopening assessment - maintainability of appeal on substantial question of law - HC [2025 (3) TMI 1587 - BOMBAY HIGH COURT] held that this appeal does not involve any substantial question of law because the jurisdictional parameters for reopening the assessment were clearly not fulfilled. ITAT has correctly pointed out that specific queries were raised and responded to. No reassessment proceedings could have been initiated based merely on a change of opinion on the same material. HELD THAT:- We are not inclined to interfere with the impugned judgment and order of the High Court; hence, the special leave petition is dismissed. Outcome: Special Leave Petition dismissed [No detailed order].
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