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        Case ID :
        Income Tax

        Reopening of assessment u/s 147 - claim of deduction u/s...

        Tax Reassessment Overruled: Court Finds No Income Escapement, Dismisses Change of Opinion by Assessing Officer.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment.
                                Note: It is a system-generated summary and is for quick reference only.
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